Who are we
West Coast Financial Advisors Ltd t/a Murray Financial Services.
West Coast Financial Advisors Ltd t/a Murray Financial Services 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 West Coast Financial Advisors Ltd t/a Murray Financial Services in relation to the information we collect, use and store about you. 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:
* West Coast Financial Advisors Ltd t/a Murray Financial Services
* Contact details for GDPR Queries are: Murray Financial Services, The Plaza Offices, Headford Rd, Galway.
* When we refer to ‘we’ we mean West Coast Financial Advisors Ltd t/a Murray Financial Services
It is important that you read this document. Please make sure anyone else named on your policy or plan has provided you with consent to provide their personal information to us.
About Our Business
Our principal business as a Financial Services Broker is to provide advice and arrange transactions on your behalf in relation to life assurance, illness cover, pension, savings & investments. Our service includes monitoring your financial products placed through our agencies and reviewing your portfolio of business with us on a regular basis.
Purpose for collecting and processing your data
As a Financial Services Broker, the personal data we collect from you is passed on to an life assurance/pensions and/or investment company or agency in order to provide you with a quotation in relation to a service you have requested, arrange a transaction on your behalf, administer, manage your policy, provide annual updates
and assist with claims as part of our service. 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 and products, 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.
The personal data we require about you (and, if applicable your business) will be gathered and stored safely as set out below. Where personal data is provided relating to a third party to us, you confirm that you have explained to them that you have provided their personal data to us and that we will process such personal data in accordance with and for the purposes outlined below.
We receive personal information about you, when you contact West Coast Financial Advisors Ltd t/a Murray Financial Services through various channels i.e., by requesting a financial review, using our website contact form, 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 product 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 product or service
* Details of beneficiaries, such as joint policy holders, beneficiaries of our products or services
* 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)
* Your general health, if relevant to the product (for example, if you are applying for life assurance/illness cover.
* Records of your contact with us such as via phone, if you get in touch with us online using our online ‘contact us’ services or details such as your mobile phone location data, IP address, records of landline telephone recordings
* Products and services you hold with us, as well existing plans/policies you may have through third parties required to adequately review your financial circumstances.
* Bank details, in order to facilitate premium payments.
* Fraud, debt and theft information, including details of money you owe, suspected instances of fraud or theft, and details of any devices used for fraud
* Financial details about you, source of income, source of wealth, details of your expenditure, and payment method(s), if relevant
* Attitude to Risk, in relation to past investments and future desired outcomes.
* Details about all of your existing borrowings and loans, if relevant
* Information about your employment status, if relevant
* Tax information, if relevant (for example, for tax planning purposes)
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 West Coast Financial Advisors Ltd t/a Murray Financial Services to provide you with any of the services we provide, West Coast Financial Advisors Ltd t/a Murray Financial Services needs to collect personal data to be able to provide a quotation, review your existing financial circumstances, arrange a transactions on your behalf, administer, manage your policy, monitor your portfolio 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 – West Coast Financial Advisors Ltd t/a Murray Financial Services 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 West Coast Financial Advisors Ltd t/a Murray Financial Services use the personal data it collected 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 or personal finances this will only be requested and processed where it is necessary for the performance of a review or inception of a life/illness policy 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 a Financial Services Broker we share your data with the life, investment and pensions companies and/or agencies we deal with in order to obtain a quotation and incept life & illness, savings, investments or pension products. 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 on our 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 permission to speak with them i.e., a relative or friend, any party named under your insurance.
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:
West Coast Financial Advisors Ltd t/a Murray Financial Services facilitate your rights under Data Protection Legislation 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. In certain cases you are obliged in the terms of your insurance contract to inform us of any changes i.e., change of address;
* 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 on-going 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.
West Coast Financial Advisors Ltd t/a Murray Financial Services 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 bank details. 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. West Coast Financial Advisors Ltd t/a Murray Financial Services will process personal data in accordance with our retention schedule. For the majority
of Policy Data, this is 6 years after the relationship ends. If you do not incept cover for a policy, your data will be kept for 12 months and processed in line with this statement. In certain cases we are obliged to hold onto records for longer periods, examples of which are public liability 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 & Automated Decision Making
We use automated decision-making, including profiling, in the following situations:
1. Risk Profiling – To establish a customer’s attitude to investment risk (relating to pensions and investments);
2. Establishing affordability and providing quotations for financial services products;
3. Providing quotes through our quote providers based on the information provided to us. The quote generated is based on the logic and criteria set by life assurance companies. An example of this would be in the case of smokers; automatically smokers pay more than non-smokers for life and illness cover.
4. Profiling for Marketing purposes – When we seek to contact you about other services, as outlined above, we run automated queries on our computerised database to establish the suitability of proposed products or services to your needs. An example would be the identification of customers who are self-employed but do not have a pension.
5. Any form of risk assessments for Fraud Prevention/Anti-Money Laundering purpose or other Legal/Regulatory reasons.
You have the right to object to profiling in certain cases only i.e., where it is not required for the performance of the contract or not required for any legal or regulatory reason.
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 West Coast Financial Advisors Ltd t/a Murray Financial Services 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 f 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 our office or emailing email@example.com. If 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.
In the event that you are unhappy with the way West Coast Financial Advisors Ltd t/a Murray Financial Services has handled your personal data, we encourage you to email us in the first instance at firstname.lastname@example.org or write to Data Protection, Murray Financial Services, The Plaza Office Suites, Headford Rd, Galway. You also have a right to lodge a complaint with the Protection Commission – email@example.com.
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact data protection on 091 740700 or email firstname.lastname@example.org
Last Updated: 2nd August 2018