Paul Murphy t/a Phoenix Financial Services 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 Phoenix Financial Services in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
- Paul Murphy
- Contact details of Paul Murphy are email@example.com or Phone 0402 33335
- When we refer to ‘we’ it is Phoenix Financial services
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?
Our principal business is to provide advice and arrange transactions on behalf of clients in relation to life, savings, investments, pensions, mortgages & general insurance products. A full list of insurers, product producers and lending agencies with which we deal is available on request.
Insurance Intermediary Services/Mortgage Intermediary Services (except for Insurance based Investment Products (IBIPs)
We act as a Broker which means that:
a) the principal regulated activities of the firm are provided based on a fair and personal analysis of the market
Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:
- Paul Murphy
- 0402 33335
Purpose for processing your data
We may use your personal information for the following purposes:
- To enable you to access and use the Services; and/or
- To personalise aspects of our overall service to you; and/or
- To communicate with you; and/or
- To use for future marketing by us, our third party providers and our affiliated companies
- To process a transaction between you and third party and or our affiliated companies.
Why are we processing your data? Our legal basis.
Our principal business is to provide advice and arrange transactions on behalf of clients in relation to life, savings, investments, pensions, mortgages & general insurance products. It is necessary for us to collect and process your personal data. We are required, therefore, to inform you of the legal bases for processing your personal data. One such legal basis is that the processing is necessary for the performance of the advisory services contract (and any other contract) that we commit to delivering to you from time to time. Another legal basis is that some processing is necessary for the purposes of the legitimate interest that we have, as a firm that is authorised and regulated by the Central Bank of Ireland, in the proper administration and correct operation of our firm. There may also be circumstances where the legal basis for processing your personal data is consent (where we have sought it and it has been provided to us), in which case that consent may be withdrawn at any time.
In any event, Phoenix Financial Services 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 Phoenix Financial Services use the personal data it collects about me?
Phoenix Financial Services 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?
We may pass your personal data on to third-party service providers contracted to Phoenix Financial Services 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 Phoenix financial services 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.
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:
Phoenix Financial Services 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
- 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. Phoenix financial services will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body Financial services ombudsman and our internal governance.
In the event that you wish to make a complaint about how your personal data is being processed by Phoenix Financial Services or how your complaint has been handled, you have the right to lodge a complaint with the Organisation Name’s data protection representatives Data Protection Officer / GDPR Owner.
You may also lodge a complaint with the Data Protection Commission in Ireland, whose details are:
Data Protection Commission
Co. Laois, R32 AP23
Phone: + 353 57 868 4800 / + 353 761 104 800
Fax: + 353 57 868 4757
Failure to provide further information
If we are collecting your data for a contract x 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
Financial and mortgage 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 customers attitude to various levels of risk having answered a series of questions.
b) Profiling for marketing purposes.
When we seek to contact you about other services, as outlined above * we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.
c) Establishing affordability and providing quotations for financial services products.
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 0402 33335 or firstname.lastname@example.org