Bellwether Financial Planning 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 Bellwether Financial Planning in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
- Barry Mooney
· Contact details: firstname.lastname@example.org
· When we refer to ‘we’ it is Bellwether Financial Planning
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?
Bellwether Financial Planning is an award-winning firm specialising in all aspects of Financial Planning. Based in Dublin, our director lead service offers advice on pensions, protection, savings and investments, estate planning and day to day financial management.
Our GDPR Owner and data protection representatives can be contacted directly here:
- Barry Mooney
· 01 4958774
Purpose for processing your data
· We need to know your basic personal data in order to provide you with ongoing organizational updates and funding information and analysis services in line with the relevant contract (s). We will not collect any personal data from you which we do not need in order to provide and oversee our services to you.
· This information is used in order to assist us making recommendations in your best interest. Some of this data will be shared with product providers for the purposes of establishing a contract with the provider. If a contract is established, you will consent to providing this information to the product provider through the completion and signing of their proposal form.
· All the personal data we process is processed by our staff in Ireland however for the purposes of IT hosting and maintenance this information is located in servers within the European Union. No 3rd parties have access to your data unless the law allows them to do so.
· We have a Data Protection regime in place to oversee the effective and secure processing of your personal data
Why we are processing your data? Our legal basis.
In order for us to provide you with Financial Planning services Bellwether Financial Planning need to collect personal data. Our reason (lawful reason) for processing your data under the GDPR is:
- Legal basis – Bellwether Financial Planning 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 e.g. a pension, protection or investment/savings contract with a product provider.
In any event, Bellwether Financial Planning 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 Bellwether Financial Planning use the personal data it collects about me?
Bellwether Financial Planning 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?
In running and maintaining the Bellwether Financial Planning website we may collect and process the following data about you:
- Information about your use of our site using standard Google Analytics tracking which includes details of your visits such as pages viewed, which resources that you access. Such information includes traffic data, location data and other communication data.
- Information provided voluntarily by you. For example, when you register your interest in downloading guides, case studies, or entering a competition.
- Information that you provide when you communicate with us.
You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer.
We may pass your personal data on to third-party service providers contracted to Bellwether Financial Planning 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 Bellwether Financial Planning 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 may pass your personal data to are:
New Ireland Assurance, Irish Life, Zurich Life, Standard Life, Aviva, Friends First, Royal London, BCP Asset Management, Wealth Options Ltd, Newcourt Retirement Fund Managers, Blackbee Investments, Davy Select, Independent Trustee Company, Conexim Advisors Ltd, Trudy Doyle Compliance Consultants.
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:
Bellwether Financial Planning 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. Bellwether Financial Planning will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body (xxx) and our internal governance.
In the event that you wish to make a complaint about how your personal data is being processed by Bellwether Financial Planning or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Organisation Name’s data protection representatives Data Protection Officer / GDPR Owner
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.
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.
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 01 4958774 or email@example.com