Irish Pensions & Finance is committed to protecting and respecting your privacy. We wish to be transparent about how we process your data and show you that we are accountable to GDPR rules for processing your data and ensuring you understand your rights.

This privacy statement intends to explain the practices of Irish Pensions & Finance regarding the information we collect about you and other users.

For the purposes of GDPR, the data controller is:

Irish Pensions & Finance, Suites 3 & 4 Gowna Plaza, Bracetown Business Park, Clonee, Co. Meath.

Please read this statement carefully as it sets out the basis on which we will process any personal data we collect from you or that you provide to us.

Who are we?

Irish Pensions & Finance provide financial advice to Public & Private Sector employees. Our team of Qualified Financial Advisors provide clients with the tools they need to set their objectives and reach their financial goals. Irish Pensions & Finance have agencies with a number of Life Companies in Ireland, allowing us to guide our clients through the application process.

Our Data Protection Officer can be contacted directly here:

Carol Crahan

carol@ipf.ie

01 8298500

How do we collect your information, and what information do we collect?

The personal information we collect varies depending upon the nature of our services. We will endeavour to provide you with an overview of the categories of personal data our organisation collects and the purpose of using that data.

Our organisation collects personal data in the following ways if you:

• Request a service from us; for example, a 121 consultation with one of our advisors.
• Register with or use any of our websites or online applications; the Contact Us form on our website will require you to complete.
• Use our website/apps, and it installs cookies or other tracking technologies onto your device.
• Engage with us on social media; we have a Facebook and Instagram account that may require some personal details to be completed.
• Contact us with a complaint or query.
• Are applying for a position with IPF, we require certain information to progress the interviews.

What information do we collect?

The information we collect about you includes the following:

• Contact and identifying information, e.g., name, address, contact details; email, mobile, landline
  Demographic details, age, gender, marital status, lifestyle, and insurance requirements; date of birth, dependents, photo ID as well as collecting personal information about you, we may also use personal information about other people, for example, family members you wish to insure on a policy: E.g., your children/spouse.
• Family and Beneficiary Data, e.g., dependents, next of kin or nominated beneficiaries
  Employment information, e.g., role, employment status (such as full/part-time, contract), salary information, employment benefits, and employment history. This information is necessary for our Fact Find with our clients.
• Health information such as information about your health status, medical records and medical assessment outcomes; We collect medical information relating to personal habits (e.g., smoking and consumption of alcohol) and medical history. We may also process specific special categories of information, for example, information about your characteristics (biometric information) or, disability information or vulnerable status.
• Pensions and Insurance Benefits information such as current benefits, pension entitlement information, date of retirement and any relevant matters impacting your benefits such as voluntary contributions and PAO.
• Financial details, e.g., bank account details, details of your credit history and bankruptcy status, salary, tax code, third-party deductions, bonus payments, benefits and entitlement data.
  Marketing preferences: We will only send you direct marketing if you explicitly consent.  Where you have consented to us providing you with promotional offers and marketing, you can withdraw this consent at any time. We will occasionally send you marketing information where we have assessed that it benefits you as a customer and in our interests. Our methods of contact may be by email, SMS text, post or telephone.
• Online information: Our website www.ipf.ie uses cookies for data analytics purposes only. This data is used to improve the experience for the user. For further information, refer to out Cookies policy  www.ipf.ie/cookies-policy.
• Events information e.g., information about your interest in and attendance at our events, including provision of feedback forms, retirement webinars, investment webinars etc
  Social media information (e.g., likes and posts) with our social media presence; this includes, LinkedIn, Facebook please.

Searches that we undertake in relation to sanctions, money laundering and credit checks. We use the EU sanctions list provided by our Broker Information Services partners, https://www.bis-platform.com/PrivacyNotice.pdf

When our organisation collects sensitive personal data as defined within GDPR, we will ensure that we require this information and have your explicit consent and/or authorisation before our collection. Please see the further details in this Privacy Notice that outlines special categories of personal data.

Information we automatically collect:

We sometimes automatically collect certain types of information when you visit our websites and through e-mails when we communicate with you. Automated technologies may include the use of web server logs to collect IP addresses, “cookies” and web beacons. Other cookies such as functional, marketing, and analytical cookies will only be used with your consent.  Further information about our use of cookies can be found in our Cookie Notice at the footer of our web page. https://www.ipf.ie/cookies-policy.

Why do Irish Pensions & Finance need to collect and store personal data?

In order to arrange your financial consultation, we need to collect your contact and employment details. During your consultation, we will need to collect personal data to allow us to assess your current financial situation and help you define your financial needs, goals, and objectives. 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, Irish Pensions & Finance would contact you for additional consent.

How will Irish Pensions & Finance use the personal data it collects about me?

Your Personal Data will enable us to fulfil our contractual obligations concerning your request for insurance, investment, protection, pension products, independent financial advice, and quotes. Your data will be used for;

1. Performing services for our clients and prospective clients – when you require insurance/investment products, we use your data to enable us to provide the required product.
2. Statutory and other regulatory requirements. We are required to carry out various obligations which include:

• AML/Sanction checking
• Knowing your customer “Fact Find”
• Adherence to the Consumer Protection Code

3. Communicating with and marketing to you – Irish Pensions and Finance will only contact you for marketing purposes once your explicit consent has been given, for example by email, written consent or online contact form.

We use the following methods of marketing communication-:

• Email
• Letter
• SMS text
• Online webinar
• Social Media

You can opt out of receiving marketing communications from us at any time by clicking the Unsubscribe button at the bottom of our marketing emails or by emailing info@ipf.ie

4. Process claims – we will process your retirement claim, and for this process, we will require ID, POA, PPS, employer information, salary, main scheme details, and previous pensions. Death, Illness and PHI claims are processed by the Product Provider.
5. To contact you if required or to respond to any communications you might send us.
6. To administer our site including data analysis, testing, research, statistical and survey purposes.
7. Carry out our obligations arising from any contracts entered between you and us and provide you with the information, products and services you request.
8. Handling complaints – refer to our complaints policy.
9. To notify you about changes to our service if applicable, i.e. changes in legal status, movements within staffing, i.e. Financial advisor joining the company, leaving the company, any new departments opening within the company, i.e. Mortgages, Retirements, etc.

Legal Basis

We need to ensure that we process your personal data lawfully. We rely on the following legal grounds to collect and use your personal data;

• Performance of a contract: When we enter a contract with you, we will collect and use your personal data to enable us to fulfil that service.
• Legal obligation: Using some of your personal data is necessary for us to meet our legal obligations, e.g., pension contributions for Revenue Certificates and regulatory purposes to the Central Bank.
• Consent: Sometimes we may rely on consent as a legal basis for processing your information. For example, we rely on consent to collect and use personal data for criminal convictions or alleged offences.  This is used when we need to assess risk relating to an insurance policy for you. We share this information with other third parties where it is necessary to manage these services provided to you – these services include insurance underwriters, reinsurers and other insurance providers.

We may also rely on your consent to send direct marketing to you. We will ensure that we present this to you concisely.  We will also ensure that we use clear and plain language, and if you give us your consent, you can withdraw this easily at any time.

Sometimes if you refuse to provide information that we reasonably require to provide the services, we may be unable to offer you the services and/or we may terminate the services provided with immediate effect.

If you require further information on any of the above bases for processing your data, we can provide you with further details.

How we share your data

When required, we may make your information available to;

• Third parties with whom we have a relationship, where that third party provides services on our behalf. We will only provide those third parties (data processors) with the necessary information to perform the services.  We will take measures to protect your information, such as putting in place Standard Contractual Clauses and confidentiality agreements.
• Insurance Partners where we need to manage the services provided to you, such as Product Providers and insurance underwriters, reinsurers, and loss adjusters. You can refer to their privacy statements on their website for more information about their privacy practices.  See links below.
• Vetting and risk management agencies such as credit reference, criminal record, fraud prevention, data validation and other professional advisory agencies, where necessary to prevent and detect fraud in the insurance industry and take steps to assess the risk in relation to prospective or existing insurance policies and/or the services.
• Legal advisers, loss adjusters, and claims investigators, where necessary to investigate, exercise or defend legal claims, insurance claims or other claims of a similar nature;
• Medical professionals, e.g., where you provide health information in connection with a claim against your insurance policy; or when we are providing a quote for insurance.
• EU Law enforcement bodies, when required to do so by law and/or regulation, or another legal request.
• Public authorities, regulators and government bodies, where necessary for us to comply with our legal and regulatory obligations, or in connection with an investigation of suspected or actual illegal activity;
• Third-party processors: We outsource our processing operations to suppliers that process personal information on our behalf. Examples include IT service providers who manage our IT and back-office systems and telecommunications networks, and accounting and payroll providers, CRM providers. See links below. These processing operations remain under our control and we have data processing agreements in place with all our third party processors to ensure all processing is carried out in accordance with our security standards and the GDPR.
• Internal and external auditors where necessary for the conduct of company audits or to investigate a complaint or security threat.
• On the sale or re-organisation of our business whether by asset or share disposal or other transaction relating to our business.

Security

The security of your personal data is important to us, we have implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk.  We have processes in place to protect your personal data from loss, unauthorised access, misuse, alteration and destruction.

Retention

Irish Pensions & Finance  shall not keep personal data in a form that permits identification of data subjects for a longer period than is necessary.

Irish Pensions & Finance may store data for longer periods if the personal data will be processed solely for archiving purposes in the public interest, scientific or research purposes in the event of a future complaint or statistical purposes, subject to the implementation of appropriate technical and organisational measures to safeguard the rights and freedoms of the data subject.

The retention period for each category of personal data will be set out in our Retention Schedule (this is a template and should be amended to reflect your firm’s procedures) , along with the criteria used to determine this period, including any statutory obligations we have. Should you require further information, we would be happy to provide it. Only include this sentence if you are and you have the information completed.

Special Categories of Personal Data

Special categories of data are sensitive in relation to your fundamental rights and freedoms and, therefore, require specific protection when processed, as these could create significant risks to the rights and freedoms of individuals.

If we collect any special categories of personal data, such as health, add any further special category here if needed data, we will either obtain your explicit consent, or we will adhere to the Data Protection Act 2018. This Act allows us to process special categories of personal data for insurance and pension purposes. We will ensure we have suitable and specific measures in place to safeguard your rights and freedoms and the processing of your data. These measures relate to the below:

• a policy of insurance or life assurance,
• a policy of health insurance or health-related insurance
• an occupational pension, a retirement annuity contract or any other pension arrangement
• the mortgaging of a property

Data Subjects Rights:

We, Irish Pensions & Finance, 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 can request a copy of the information 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- If Irish Pensions & Finance refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved as we have indicated in processing your personal data.

Profiling – automatic decision making:

Irish Pensions & Finance may, from time to time, carry out automatic decision-making (for example, Risk Profiling or insurance underwriting) where relevant.
You will be notified in advance of any instance of this and have the right to object to this at any time.

Contact Us:

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on (01) 829 8500 or email carol@ipf.ie

Privacy notice/ statement changes:

When we update this Privacy Notice/Statement, we will post a revised version online. Changes will be effective from the point at which they are posted. We would encourage you to review our Privacy Notice so that you are aware of updates.
This privacy statement was last updated in March 2022.

3rd Party Privacy Statements:

New Ireland Assurance -> https://www.newireland.ie/utilities/privacy-statement/
Aviva -> http://www.aviva.ie/privacy/
Zurich Life -> https://www.zurich.ie/privacy-policy/
Standard Life -> https://www.standardlife.com/sl/privacy-policy.page
Irish Life -> https://www.irishlife.ie/privacy-notice
Friends First -> https://www.friendsfirst.ie/privacy/
Royal London -> https://www.friendsfirst.ie/privacy/
Blackbee -> http://blackbee.ie/privacy-policy-documents/
Broker Information Services -> https://www.bis-platform.com/PrivacyNotice.pdf
Constant Contact Email Provider->  https://www.constantcontact.com/legal/privacy-notice
Facebook – > https://www.facebook.com/policy

IPF Irish Pensions and Finance Ltd, trading as Irish Pensions and Finance, is regulated by the Central Bank of Ireland.