# # # # #
 

Privacy Notice/Statement

Introduction

Public Sector Life and Pensions Ltd 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 Public Sector Life and Pensions Ltd in relation to the information we collect about you.

For the purposes of the GDPR the data controller is:

  • Public Sector Life and Pensions Ltd
  • Contact details 064 6640951
  • When we refer to ‘we’ it is Public Sector Life and Pensions Ltd

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?

  • Public Sector Life and Pensions Ltd. has been providing financial advice to its clients since 2007 specialising in public sector employees, while its founder has been providing financial services advice to public sector employees since 1993.
  • We hold agencies with some of the largest insurance companies in the market. This puts us in the enviable position of being able to provide our clients with the best products available, suitable for their needs. With insurance companies constantly updating their products and services we pride ourselves on bringing our clients the most up to date information and rates for Income Continuance, Life Cover and Serious Illness Cover. We also research the various companies funds performance, with a view to bringing this information to our clients, so that they can make an informed decision where best to invest their Additional Voluntary Contributions ( AVC's), PRSA's, Pensions and Lump Sum Investments.
  • Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:
    Derek Hanley
    derek@publicsector.ie
    064 6640951

    Why we are processing your data? Our legal basis.

    In order for us to provide you with advice in relation to Life, Pensions and Investments Public Sector Life and Pensions Ltd need to collect personal data for the provision of these services. Our reason (lawful reason) for processing your data under the GDPR is:

    Legal basis – Public Sector Life and Pensions Ltd 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.

    Purpose for processing your data

    We need to collect and use your personal information to arrange for your policy contract through the relevant insurer who underwrites any policy you choose to go ahead with. The information collected includes, but is not limited to, your name, date of birth and contact details. Depending on the policy type this can include health, employment, pension and salary information. We restrict access to, and the use of, special categories of data and other sensitive personal information. The personal information needed for policy contracts is held and used to:

    • Verify your identity and to verify the accuracy of the information we receive about you
    • Assess the information you have provided, and make a decision as to whether we can provide you with cover through the relevant insurer
    • Provide you with a quotation for a product and to arrange for the provision of specific insurance cover should you decide to purchase a product through Public Sector Life and Pensions Ltd
    • Share your personal information with the relevant insurer to ensure that you have the appropriate cover in place
    • Provide you with information about your policy
    • Provide customer care and service – to administer your policy and make any changes during its term, answer queries, provide updates or process a cancellation
    • Contact you to inform you of any relevant actions you may need to take
    • Receive any payments in relation to your policy for onward transmission to the relevant insurer where appropriate
    • Assist you in the making of a claim through the relevant insurer.

    In any event, Public Sector Life and Pensions Ltd 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 Public Sector Life and Pensions Ltd use the personal data it collects about me?

    Public Sector Life and Pensions Ltd 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 pass personal information to:

    Insurers: We share your personal information with the relevant insurer(s) to provide you with quotations, to process your applications, to ensure that you have the appropriate cover in place and to process claims where relevant.

    Your Authorised Representatives: We share your personal information with third parties you have nominated to deal with our company on your behalf.

    We may pass your personal data on to third-party service providers contracted to Public Sector Life and Pensions Ltd 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 Public Sector Life and Pensions Ltd 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 pass your personal data to are:

    Regulators and other official agencies: Regulators, an Garda Síochana, the Revenue Commissioners, other official agencies or as needed to comply with regulations and laws and on foot of a Court Order or Subpoena.

    Do we transfer your personal data outside of The European Economic Area (EEA)?

    Your personal information is processed and stored within the EEA.

    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:

    Public Sector Life and Pensions Ltd facilitate you, our clients, 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 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 Public Sector Life and Pensions Ltd 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. Public Sector Life and Pensions Ltd will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body and our internal governance.

    Complaints

    In the event that you wish to make a complaint about how your personal data is being processed by Public Sector Life and Pensions Ltd 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.

    Profiling – automatic decision making

    The relevant insurer for your policy may use automated decision making in the calculation of premiums or during the underwriting process in order to provide you with cover. Please refer to the relevant insurer’s Data Privacy Notice for more information in relation to this.

    Where any automated decision making used by the insurer produces legal effects for you or otherwise significantly affects you, you will have the right to obtain human intervention and to contest and make representations in relation to the decision in question.

    An example;
    Profiling – automatic decision making

    Profiling;
    Financial advisors using profiling in their business. The main categories are

    • Risk profiling.
    • Profiling for marketing purposes.
    • Establishing affordability and providing quotations for financial services
      • 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.
      • Profiling for marketing purposes. When we seek to contact you about other services, we run automated queries on a computerised data base to establish the suitability of proposed products or services to your needs.
      • Establishing affordability and providing quotations for financial services products.

    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.

    Contact Us

    Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 064 6640951 or email; derek@publicsector.ie

    Privacy policy statement changes

    Public Sector Life and Pensions Ltd may change this privacy policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically so you’re aware of any changes. By using our services you agree to this privacy policy.

    This privacy policy was last reviewed in May 2018