Your Privacy is important to us.
We understand that in the course of doing business together, you are likely to share confidential information about yourself, your family and your financial circumstances that you wouldn’t want shared with anyone else, and we completely understand why.
It is however, important that you understand the circumstances in which we must share some of your information with other solution providers in order to provide the service we give to you. The policy below will outline who and what we share with these 3rd party providers, as well as your rights to access and correct any information, and our obligations under GDPR.
Rest assured, we only share what we need to and have strict rules around this.
FM Downes LTD Privacy Policy
At FM Downes LTD we are committed to ensuring the privacy of your information and will only ask for personal information that is relevant in order to answer a specific query or process a specific task (e.g., your name, address, email etc)
We do not forward information about you to any third party, except as required by law.
This Privacy Notice sets out the bases on which we gather, use, process and disclose any Personal Data we collect about you, or that you provide to us.
This Privacy Notice applies to you, whether you are a current, past or prospective customer. It also applies to third parties whose Data you provide to us in connection with our relationship with you (for example, the names of relatives). Please ensure that you provide a copy of this Privacy Notice to any third parties whose personal data you provide to us.
We control your Personal Data to allow us to give you advice and recommendations on your financial affairs, your data is then passed on to the relevant company/companies we have agencies with by way of application forms, by post email or through their secure websites online.
Data we may collect about You
In order for us to give you a recommendation and information on financial products, we need to collect and process personal information about you. If you do not provide the information we need, we may not be able to offer you advice or provide our services to you. The types of personal data that are processed may include: • Individual details – Name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title and employment history, and family details, including their relationship to you. • Financial detail – full details on any debts, loans assets you may own. • Identification details – Identification numbers issued by government bodies or agencies, including your PPS Number, passport number, tax identification number
Special Categories of Personal Data
Health information which has additional protection under Data Protection Law. We do not process health information other than hold the information on application forms you have filled in. The Life Insurers process and control your health data to allow them to underwrite your policy or decide decline cover, they may have further information they have obtained with your approval from your doctor, but we are not privy to this information. • Claims information – information you give us with regards claims you notify us about or ask for help on. • Policy Information – Information about the quotes you receive and policies you take out
Where We May Collect Your Personal Data From
We may collect your personal data from various sources, including. • You • Your employer or representative • Life Companies we have agencies with • When you sought a quote from us • If you have or had any other contracts of insurance that is not under our agencies • In this instance, we will need a letter of authorisation from you to allow us contact other companies on your behalf • When you visit our website and input a request for us to contact you. Which of the above sources apply will depend on your particular circumstances and the product or service you are interested in or your enquiry relates to.
Legal Bases for Processing Your Information
We will only use your Personal Data for lawful reasons. These are: a) The use is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering a contract (such as providing a recommendation). b) The use is necessary to comply with our legal obligations. c) You have consented to us using your information in such a way. d) The use is necessary for the purpose of our legitimate interests. e) The use is necessary for the performance of a task carried out in the public interest, such as assisting a regulatory authority’s investigation of a criminal offence
The Purpose of Processing Your Information
- To give you information on and provide you with recommended financial products.
- Disclose data to policyholder, life assured, beneficiary, trustee, assignee, successors, group company or to other parties.
- To comply with legal and regulatory requirements including Anti-Money Laundering and Sanctions compliance.
- To understand how people, interact with our websites (if applicable).
- To carry out and determine the effectiveness of advertising, and of marketing campaigns.
How long do we keep Your Information?
When providing products to you it may be necessary to retain your information for an extended period of time. We keep your information for as long as required by law for the purpose that you gave it to us for. As a general rule for legal and best practice reasons we are required to keep your information for 6 years after the date on which our relationship with you ends.
Your Rights to Access, Transport, Correct, Delete and Restrict the Use of Your Personal Data
You have the right to access a copy of your Personal Data which we hold on you. In the case of Personal Data, you provided to us to process on the basis of your consent or for automated processing, you have the right to have it provided in a commonly used electronic format to you or to another Data Controller (subject to applicable Data Protection Law). If you would like a copy of your Personal Data, please contact us. Your request will be dealt with as quickly as possible and in any event within a month for us to respond. If at that stage, we are unable to provide the data you require (due to the complexity or number of requests) we may extend the period to provide the data by a further two months but shall explain the reason why. There is no charge for the request for your data, but it must be in writing or email.
You have the right to have your Personal Data corrected if you feel we have incorrect data held on you
Deleting Your Personal Data
Subject to any overriding legal obligation requiring us to retain it, you have the right to have your Personal Data deleted, however erasing your information may make it difficult or impossible for us to give you information on, provide you with, or administer our financial products. If you want your information deleted, please contact us.
Restricting our use of your Personal Data
You have the right to restrict our use of your Personal Data in certain circumstances. If you wish to exercise your rights in this regard, please contact us.
Automated/Profiling Decision Making
Where we use automated decision-making, you will always be informed & you will be entitled to have a person review the decision so that you can contest it and put your point of view and circumstances forward. E.g., When we produce quotes for the business you are contacting us about. When we want to market to you, we may run a program which allows us to identify certain criteria of clients (all those with that fit within a certain criterion for example).
Your Right to Object and Withdraw your Consent to Data Processing
Where our lawful basis for processing your Personal Data is based on our legitimate interests, you have the right to object. You also have the right to withdraw your consent to any processing at any time. However, if we cannot process your data, it may make it difficult, impossible or unlawful for us to give you information on, provide you with, advice on financial products. If you want to object or withdraw your Consent to processing, please contact us.
Your Right to Make a Complaint
If you are dissatisfied about the way, we handle your Personal Data please contact us. We will do our best to address your concerns swiftly and resolve any issues you have. You have the right to complain to the Office of The Data Protection Commission, Canal House, Station Road, Portarlington, Co. Laois, R32 AP23. www.dataprotection.ie Tel.: +353 (0)761 104 800. Fax: +353 57 868 4757. E-Mail: info@dataprotection.ie
It is the policy of FM Downes LTD:
∙ To comply in full with the requirements of all Data Protection legislation and codes
∙ To develop our Data Protection compliance procedures on a “best practise” basis
∙ To obtain and process information fairly
∙ To keep it only for one or more specified, explicit and lawful purposes.
∙ To use and disclose it only in ways compatible with these purposes
∙ To keep it safe and secure
∙ To keep it accurate, complete and up to date
∙ To ensure that it is adequate, relevant and not excessive.
∙ To retain it for no longer than is necessary for the purpose or purposes.
∙ To respond to access requests as required by law.
At FM Downes LTD Insurance we understand how important the security and confidentiality of your information is to you. Keeping customers’ information secure is a top priority for ours. Our goal is to protect your information on the Internet in the same way as we would our normal business information.
However, public internet email is a communication channel which cannot be guaranteed to be secure. As such, there are no guarantees that any email or its contents; will be delivered within a reasonable timeframe or at all, has not been intercepted by a third party, are unaltered from the time of transmission.
All personal data that is received by FM Downes LTD is kept on our secure system using appropriate physical and technical measures which are reviewed regularly.
Tel 01 855 6666 | info@fmdownes.com | www.fmdownes.com
Registered Office: Kandoy House, 2 Fairview Strand, Dublin 3
FM Downes LTD is regulated by the Central Bank of Ireland.