Privacy Statement
S.A. Faughnan (Brokers) 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 S.A. Faughnan (Brokers) Ltd. in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
S.A. Faughnan (Brokers) Ltd.
Contact details of S.A. Faughnan (Brokers) Ltd. 003531 824 5555 / gdpr@safaughnan.ie / www.safaughnan.ie
When we refer to ‘we’ it is S.A. Faughnan (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?
S.A. Faughnan (Brokers) Ltd. is an Investment Intermediary regulated by the Central Bank of Ireland. We are a member of Brokers Ireland. Our principal business is to provide advice and arrange transactions on behalf of clients in relation to general (non-life) insurance products, life assurance, pensions and investment products.
Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:
David Faughnan gdpr@safaughnan.ie – PH 00353 1 824 5555
Purpose for processing your data
We collect risk related data from you (which may include some personal data e.g. date of birth, address and contact numbers / email / insurance history / personal disclosures) for the purposes of building a detailed risk submission for onward presentation to our panel of insurance markets in order to obtain pricing and terms for insurance products which we deem necessary for the risk(s) you have presented and which provide insurance protection for many of the exposures you face, where available. We do not use your personal data for any other reasons than stated above.
We do not share your personal data with any third parties, unless required by the terms of a policy of insurance e.g. risk surveys / claims adjusting / handling. Relevant risk detail (e.g. risk address, tenancy types, previous insurance claims or relevant personal disclosures (e.g. criminal convictions)) will be disclosed to various insurers for the purposes of assessing risk acceptance, pricing and terms of cover. This information is in the main transacted with insurers by email or via online insurance portals.
Why we are processing your data? Our legal basis.
In order for us to provide you with advice and arrange transactions on your behalf in relation to general (non-life) insurance products, life assurance, pensions and investment products S.A. Faughnan (Brokers) Ltd. need to collect personal data to provide you with advice and arrange transactions on your behalf in relation to general (non-life) insurance products, life assurance, pensions and investment products
To use your information lawfully, we rely on one or more of the following legal bases:
- your consent;
- performance of a contract;
- legal obligation (e.g. “Minimum Competency Code”, “Fitness & Probity”, TCA 1997);
- protecting the vital interests of you or others;
- public interest; and
- our legitimate interests or the legitimate interests of a third party (e.g. your employer).
Our reason (lawful reason) for processing you data under the GDPR is:
Contractual – S.A. Faughnan (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 relation to general (non-life) insurance products, life assurance, pensions and investment products.
In any event, S.A. Faughnan (Brokers) 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 S.A. Faughnan (Brokers) Ltd. use the personal data it collects about me?
S.A. Faughnan (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 endeavor 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) we will ensure that specific measures are being taken to safeguard the fundamental rights and freedoms of data subjects. The processing of data concerning health is lawful where it is necessary and proportionate for the purposes of:
- 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, or
- the mortgaging of property
Who are we sharing your data with?
We may pass your personal data on to relevant third-party service providers contracted to S.A. Faughnan (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 fulfill 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 S.A. Faughnan (Brokers) Ltd. procedures.
The third parties that we pass your personal data to are:
- Our CRM providers
- Non-Life (General Insurance) Product Providers
- Life Assurance Product Providers
- Pension Providers
- Life Wrapped Investment Providers
- Bond Investment Providers
- Insurance Surveyors (where it is a condition of your insurance policy terms)
- Claims Loss Adjusters (where you have made a claim or had a claim made against you in relation to your policy of insurance)
We have issued all our third party processors with Standard Contractual Clauses – these are based on the Standard Contractual Clauses adopted by the European Commission.
If you hold insurance against a liability that may be incurred by you against a third party, where for whatever reason you cannot be found or you become insolvent, or the court finds it just and equitable to so order, then your rights under the contract will be transferred to and vest in the third party even though they are not a party to the contract of insurance. The third party has a right to recover from the insurer the amount of any loss suffered by them. Where the third party reasonably believes that you as policyholder have incurred a liability the third party will be entitled to seek and obtain information from the insurer or from any other person who is able to provide it concerning:
- the existence of the insurance contract,
- who the insurer is,
- the terms of the contract, and
- whether the insurer has informed the insured person that the insurer intends to refuse liability under the contract.
Data Subjects Rights:
S.A. Faughnan (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.
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.
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. S.A. Faughnan (Brokers) 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), the FSPO and our internal governance.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by S.A. Faughnan (Brokers) Ltd. or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and S.A. Faughnan (Brokers) Ltd.
You may also contact the Data Protection Commission in Ireland to lodge a complaint (details below).
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
Web: www.dataprotection.ie Email: info@dataprotection.ie
Failure to provide further information
If we are collecting your data for a contract (e.g. life policy or motor insurance policy) 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
S.A. Faughnan (Brokers) Ltd. whilst providing advice on the suitability or otherwise of financial products use a CRM system called Money Advice which provides broker assistance in assessing the levels of cover required by a customer on the basis of the personal and risk data entered in to the system. This automated assistance is a guideline tool only and the financial advisor will use his / her own experience to advise on the levels of cover whilst using Money Advice as an assistance tool.
Financial advisors using profiling in their business. The main categories are
- a) Risk Profiling
To establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the customer’s attitude to various levels of risk having answered a series of questions.
- b) Establishing affordability and providing quotations for financial services products.
You can object to this at any time by contacting us in writing at gdpr@safaughnan.ie making specific mention of your concern.
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 00353 1 824 5555 or at gdpr@safaughnan.ie .
Privacy policy statement changes
SA Faughnan may change this privacy statement 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 statement periodically so you’re aware of any changes. By using our services you agree to this privacy statement.
This privacy statement was last reviewed in September 2021
S.A.Faughnan (Brokers) Ltd. is regulated by the Central Bank Of Ireland
Directors: S.A. Faughnan, M.R. Faughnan, D.A. Faughnan.
Registered in Ireland No. 88953. Registered Address (as above).
