Introduction
Provest Private Clients Limited thereafter referred to as ‘Provest,’ is committed to respecting and protecting your privacy.
Provest recognises that protecting personal information is very important to you. It is the intention of this privacy notice statement to explain to you the information practices of Provest in relation to the information we collect, use and store about you. We wish to be transparent on how we process your data and show you the we are accountable with GDPR in relation to not only processing your data but also ensuring you understand your rights as a client. It is supplemental to the Data Protection Notice provided to you in our Terms of Business. It sets out in more detail how we handle and manage your personal information including sensitive data we may process. Personal data relates to you, anyone insured under your policy or anyone whose personal data we process in connection with your policy/portfolio and applies to all your dealings with us.
For the purposes of the General Data Protection Regulations (GDPR) the data controller is:
· ‘Provest’
· Contact details for GDPR Queries at Provest are: 5 The Mall, Maryborough Hill, Douglas, Cork T12 XN97. Telephone No. 353 21 201 0123 or Email info@provest.ie
· When we refer to ‘we’ we mean Provest.
It is important that you read this document and show it to anyone else who is insured or named under your policy of insurance. Please make sure anyone else insured or named under your policy has provided you with consent to provide their personal information to us.
Who are we?
Our principal business as an impartial adviser is to provide advice and arrange transactions on your behalf in relation to Pension Advisory & Investment Advisory services.
Purpose for collecting and processing your data
As an impartial adviser we will be responsible for, the personal data we collect from you is passed on to an insurance company in order to obtain a premium and provide you to provide these services you have requested, to arrange and transact on your behalf. We may also collect your personal data to verify your identity or to compile and process your information for audit, statistical or research purposes, for compliance with regulatory and legal requirements, for internal record keeping and to protect your vital interests. We may also process your personal data where we have a legitimate interest to do so, subject to those interests not over-riding your fundamental rights and freedoms. This includes: market research and statistical analysis to improve our services, to protect our business, reputation, resources and equipment, manage network and information security and prevent and detect fraud, dishonesty and other crimes, investigating complaints, training and monitoring staff.
We receive personal information about you, when you contact Provest through various channels i.e., using our website’s or telephone, post, email or by visiting our office.
The personal data we will collect from you and process, where relevant, is dependent on the type of service you are seeking, this is not a limited list and may include:
· Personal, such as title, full name, address, landline telephone number, mobile number, work number, email address
· Your date of birth, gender and/or age, PRSI number,
· Your nationality, residency and/or citizenship status, if needed for the placing of a product or service
· Details of beneficiaries, such as joint policy owners, beneficiaries of the product or service
· Family members (if relevant to the product or service)
· Your marital status, family, lifestyle or social circumstances, if relevant to the product (for example, the number of dependents you have or if you are a widow or widower), or service
· Records of your contact with ussuch as via phone, landline or mobile
· Information about your use of products or services held with the firm, such as other insurance policies, savings or financial services and products
· Information about your health or if you are a vulnerable customer.
· Information about your assets and liabilities, income and expenditure.
· Financial details about you, source of income, source of wealth, details of your expenditure, and payment method(s), if relevant
· Details about all of your existing borrowings and loans, if relevant
· Information about your employment status, if relevant
Note: Some personal data is mandatory in order for the performance of the contract. In the event you decide not to provide the mandatory personal data we will be unable to provide you with a certain service or product. We will indicate to you where any personal data required is mandatory or optional.
Why we are processing your data? Our Legal Basis.
In order for Provest to provide you with any of the insurance services listed above, Provest needs to collect personal data to be able to provide the services you have requested, arrange a transactions on your behalf, administer, manage your policy and assist with claims as part of our service.
Our reason (lawful reason) for processing your data under the EU’s General Data Protection Regulation (GDPR) is:
· Legal basis – Provest needs to collect and process your data on the basis that it is necessary to do so to enter into and/or to perform a contract with you.
We are committed to ensuring that the information we collect, and you give us is appropriate for this purpose, and does not constitute an invasion of your privacy.
How will Provest use the personal data is collects about me?
We will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulations (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.
Where we collect any special categories of personal data, known as ‘sensitive data’ i.e., data about your health. this will only be requested and processed where it is necessary for the performance of an insurance contract and will only be processed by way of
a) explicit consent
b) assessment of risk
c) for the prevention of fraud
d) for the establishment, exercise, enforcement or defence of legal claims, or
e) to protect the vital interests of a person.
Who we are sharing your data with?
As an impartial adviser we share your data with the insurance companies and Qualifying Fund Managers we deal with in order to obtain a quotation, negotiate investment terms and the provision of alternative quotations, where relevant, for you. Any third parties that we may share your data with are obliged to keep your details secure, and 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 relevant details. In order to fulfil our legal and regulatory obligations we may also share your personal data with any authorities for example: The Data Protection Commission, Revenue Commissioners, Central Bank of Ireland, Financial Services and Pensions Ombudsman, our legal advisors or the Garda Siochana. When we believe we have been given false or misleading information, or we suspect criminal activity we must record this and inform the relevant authorities. Your data is held within the Provest office network and may be shared with any providers or suppliers where the firm outsources the processing of certain functions, for example: Auditors, Legal advisors, IT/Software providers, Payment Processes or other third parties involved in administering your contract. Your data may also be shared with any party where you have given us your explicit consent to do so i.e. to speak with a relative or friend or third party.
In the instance where we have to transfer data outside the European Economic Area (EEA) to help provide you with products and services, we will do so in compliance with obligations under Data Protection Legislation and would expect the same standard of data protection is applied outside of the EEA to these transfers and the use of the information, to ensure your rights are protected.
Data Subjects Rights:
Provest facilitate our client rights in line with Data Protection Legislation and our policy to address any concerns or queries about the processing of your personal data. 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;
· Rights of Rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
· Right to Withdraw Consent – you have the right to withdraw your consent to your data being processed where we use consent as the legal basis;
· Right to be forgotten – you have the right to have your personal data deleted or to be forgotten. However, we can only delete your data in certain circumstances and there may be instances where we cannot provide a deletion i.e., an ongoing claim;
· Right to restriction of processing – where certain conditions apply you have a right to restrict the processing of your data;
· 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 be excluded from profiling or automated processing; you also have the right to be subject to the legal effects of automated processing or profiling;
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.
Data security
Provest intent is to strictly protect the security of your personal information; honour your choice for its intended use; and carefully protect your data from loss, misuse, unauthorised access or disclosure, alteration or destruction. We have taken appropriate steps to safeguard and secure information we collect online, including the use of encryption when collecting or transferring sensitive data such as credit card information. However, you should always take into consideration that the internet is an open forum and that data may flow across networks with little or no security measures, and therefore such information may be accessed by people other than those you intended to access it.
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 it was obtained. Provest will process personal data in accordance with our retention schedule. In certain cases, we are obliged to hold onto records for longer periods, examples of which are insurance and pension details. We do so in line with our regulatory obligations.
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 -Atomised decision making
We do not carry out any profiling .
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. Where we have your consent to send you information about any other products, services or offers which Provest would like to communicate to you, we may contact you through a variety of means such as mobile phone, landline, email, SMS (text) and post. This can include you being contacted on or about the anniversary of your policy lapsing or your quote request. It is always your choice whether you want to receive any marketing-based information. You can also change your preferences of how we contact you or amend how you receive any marketing at any time by calling your local branch or emailinginfo@provest.ieIf you choose not to receive this type of information, it will not affect any of the services provided to you, now or in the future.
Complaints
In the event that you are unhappy with the way Provest has handled your personal data, we encourage you to email us in the first instance at dataprotection@provest.ieor write to Provest Private Clients Limited, 5 The Mall, Maryborough Hill, Douglas, Cork T12 XN9Y. You also have a right to lodge a complaint with the Ombudsman, Lincloln House, Lincoln pl, Dublin 2, D02 VH29.
Contact Us
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact Provest on 353 21 201 0123 or email info@provest.ie
Privacy Policy Statement Changes
We may change this privacy policy from time to time. When such a change is made, we will post a revised version on our website. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically, so you are aware of any changes. By using our services, you agree to this privacy statement.
This privacy statement is effective from