Privacy Notice / Statement
Hardiman Life & Pensions 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 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 Hardiman Life & Pensions Limited in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
- Hardiman Life & Pensions Limited
- Contact details of Hardiman Life & Pensions Limited)
- When we refer to ‘we’ it is Hardiman Life & Pensions Limited
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?
Hardiman Life & Pensions Limited are financial brokers who provide bespoke financial advice to individuals, employees and business owners. We provide advice about savings, investments, pensions, life insurance, serious illness, income protection and general financial planning.
Our GDPR Owner and data protection representatives can be contacted directly here:
- Daniel Hardiman
- 093 70007
Why we are processing your data? Our legal basis.
In order for us to provide you with financial advice, we need to collect personal data to provide the appropriate recommendations for your circumstances. Our reason (lawful reason) for processing your data under the GDPR is
- Legal basis – we need to process your data as this is necessary in relation to recommending a particular financial product. We need to assess your financial circumstances in order to ensure the financial product we recommend is suitable for your circumstances. We are required by law to collect your personal information to set up an insurance contract or investment product.
In any event, we 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 Hardiman Life & Pensions Ltd use the personal data it 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 Regulation (GDPR). We will endeavor 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) – we will ensure to 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 Hardiman Life & Pensions 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 fulfill 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 their 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:
- Aviva Life & Pensions,
- J&E Davy
- BCP Asset Management
- KBC Bank Ireland Ltd
- BES Management Ltd
- New Ireland Assurance plc
- Cantor Fitzgerald Ireland Ltd
- Phoenix Ireland
- Royal London
- Friends First Life Assurance Company
- Wealth Options
- Independent Trustees Ltd
- Zurich Life Assurance Plc
- Irish Life Assurance Plc
- Blackbee Investments
- Key Capital
- Business Information Systems
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:
We 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 – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that Hardiman Life & Pensions Limited 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:
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. We will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body, Central bank of Ireland and our internal governance.
In the event that you wish to make a complaint about how your personal data is being processed by Hardiman Life & Pensions Limited or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Hardiman Life & Pension’s data protection representatives – 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
- 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
- a) Establishing affordability and providing quotations for financial services products.
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 093 70007 or email firstname.lastname@example.org