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General Data Protection Regulation
Peter Duggan Financial Services Limited 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 General Data Protection Regulation (GDPR) in relation to not only collecting and processing your data but ensuring you understand your rights as a client. Peter Duggan Financial Services Ltd is the “Controller” of the personal data you provide to us.
It is the intention of this summary notice to explain to you the information practices of Peter Duggan Financial Services Limited in relation to the information we collect about you.
For the purposes of the GDPR the data controller and GDPR Owner is:
• Peter Duggan
• Telephone No.: +353 (0)61 49 00 50
• Email address: firstname.lastname@example.org
• When we refer to ‘we’ it is Peter Duggan Financial Services Limited
Please read this statement carefully as it 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?
Peter Duggan Financial Services Ltd is a Multi-Agency Intermediary based in Limerick. We have operated in the Mid-West Region since September 1989. We pride ourselves on providing financial analysis appropriate to our corporate and individual clients circumstances. We provide advice and arrange transactions on behalf of clients in relation to life, pensions and investments products.
Purpose for processing your data
• To maintain client relationships; ongoing policy administration
• To verify your identity
• To provide Financial Services & Advice
• To complete and process life, pension and investments contracts and to process claims
Our legal basis
For us to provide you with Financial Services & advice we need to collect personal data to provide protection quotes and process life, pensions and investments contracts and claims. Our lawful reason for processing your data under the GDPR is:
Legal basis - Peter Duggan Financial Services Ltd needs to collect and process your data as this is necessary in fulfilling life/pension & investment contracts to which you have entered into, or because you the individual has asked for something to be done so you can enter into a contract or to process a claim.
Peter Duggan Financial Services 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 Peter Duggan Financial Services Ltd use the personal data it collects about me?
Peter Duggan Financial Services Ltd will process (collect, store and use) the information you provide in a manner compatible with the EUs’ 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 i.e. health data, we will obtain your explicit consent (this consent can be withdrawn by you at any time).
Who are we sharing your data with?
We share your personal data with our Product Providers (available on request) to complete the set up and administration of all life, pensions and investments contracts and to process any claims that may arise and with Broker Information Systems who own the Customer Relationship Management (CRM) database we use. All data is encrypted with security safeguards in place to protect your information. (Our full Data Protection Policy & Cybersecurity Policy is available upon request).
Peter Duggan Financial Services Ltd will never use or pass on to any third party any personal data for marketing purposes.
If we are requested by you as the data subject, to pass your personal or sensitive personal data onto a third party (i.e. accountant, other Financial Advisor, mortgage advice) we will only do so once we have obtained your explicit consent, unless we are legally required to do otherwise. We have contracts in place with all our Product Providers and suppliers, which protect your and our rights under the GDPR.
We do not currently transfer any data to other countries within the EEA or outside the EEA. Should it be necessary to do so, 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:
Peter Duggan Financial Services Ltd facilitate your 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 find out what information we hold about you.
• Right of rectification – If any of your details are incorrect or incomplete you can ask us to correct them for you.
• 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
• Right to judicial review: should Peter Duggan Financial Services Ltd refuse your request under rights of access, we will provide you with a reason as to why.
All the above access 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, normally 6 years (7 years for Investment contracts) for the purpose(s) for which they were obtained. We will process personal data in accordance with our retention schedule (available upon request). This retention schedule has been governed by our regulatory body the Central Bank of Ireland, the Financial Services & Pensions Ombudsman (FSPO) and our internal governance.
If you wish to make a complaint about how your personal data is being processed by us or how a complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority. You can contact the Office of the Data Protection Commission at:
Data Protection Commission
Telephone No.: 0761 104 800
Lo Call No.: 1890 252 231
Failure to provide further information
If we are collecting your data for a contract and you cannot or do not want to provide this data, the consequences of this could mean the contract cannot be completed or details are incorrect.
Profiling – automatic decision making
When establishing affordability and providing quotes for Financial Services such as Protection contracts we use an online quotation system (through Broker Information Services) to do this. We use the information you provide to us to acquire the best quote.
Automated decisions are made when it comes to underwriting a policy. You have the right to object to the automated underwriting decisions made by our Product Providers in certain circumstances.
To establish a customers’ attitude to investment risk (relates to pensions and investments) we use automated calculators which calculate your attitude to various levels of risk after having answered a series of questions. This is necessary to identify the level of investment risk you are prepared to take enabling us to advise you according to your risk rating.
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 +353 (0)61 49 00 50 or email email@example.com.
This privacy notice was last reviewed 24 May 2018
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