Privacy Notice/Statement
Introduction
PM Brennan Financial Brokers Ltd t/a IHI Group 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 PM Brennan Financial Brokers Ltd in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
PM Brennan Financial Brokers Ltd
When we refer to ‘we’ it is PM Brennan Financial Brokers 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?
We are a composite firm of financial advisors providing impartial advice, analysis and professional services on a wide range of financial and insurance solutions.
Our GDPR Owner and data protection representatives can be contacted directly here:
01 403 0700
Our Remuneration
Please click here for Our Remuneration policy/information.
Purpose for processing your data
We use your personal data to provide you with advice on your financial needs, arrange a suitable insurance cover or investment product and offer customer service. The personal information includes but is not limited to your name, date of birth and contact details.
In relation to advice and services regarding pensions, investments and life insurance we will collect sensitive personal information. The access to this information will be restricted and they will be used only in relation to providing you with the products/services requested.
Why we are processing your data?
Our legal basis
In order for us to provide you with our services, PM Brennan Financial Brokers Ltd need to collect personal data for analysis and arranging suitable product solutions. Our reason (lawful reason) for processing your data under the GDPR is:
Legal basis
PM Brennan Financial Brokers 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, PM Brennan Financial Brokers Ltd is 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 PM Brennan Financial Brokers Ltd use the personal data it collects about me?
PM Brennan Financial Brokers 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 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 PM Brennan Financial Brokers 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 PM Brennan Financial Brokers 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.
The third parties that we pass your personal data to are:
Insurers & Investment Companie
System administrators e.g. Broker Information Services Ltd, ASE Software Ireland Ltd, Voyant
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
PM Brennan Financial Brokers Ltd facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request.
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 PM Brennan Financial Brokers Ltd refuses your request under rights of access, we will provide you with a reason as to why.
All of theabove requests will be forwarded should there be a third party involved as we have indicated in the processing of your personal data.
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which it was obtained. PM Brennan Financial Brokers 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 PM Brennan Financial Brokers Ltd or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and data protection representatives.
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
We use the following categories of profiling in our business:
- Risk profiling
- Profiling for marketing purposes.
- Establishing affordability and providing quotations for financial services and insurance services
- Psychometric profiling for recruitment purposes
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 and insurance products
To obtain quotation and establish affordability, we run personal risk details on our quotation systems.
d) Psychometric profiling for recruitment purposes
We carry out psychometric testing on potential employees for recruitment purposes.
Please be advised that at any point you have the right to object to carrying out of these procedures.
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 (01) 403 0700 or email info@pmbrennan.ie
Privacy Policy Statement Changes
PM Brennan Financial Brokers 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