Introduction
Secure Life Planning Ltd t/a Life Planning 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.
This document is being provided to you in line with our obligations under the General Data Protection Regulation (GDPR), which came into force on 25th May 2018. From that date, the GDPR, together with applicable Irish requirements, will amend existing data protection law and place enhanced accountability and transparency obligations on organisations when using your information. The GDPR will also introduce changes which will give you greater control over your personal information, including a right to object to processing of your personal information where that processing is carried out for our business purposes.
It is the intention of this privacy statement to explain to you the information practices of Secure Life Planning Ltd t/a Life Planning Ltd in relation to the information we collect about you and what rights you have in relation to your personal information. When we refer to ‘we’ it is Secure Life Planning Ltd t/a Life Planning Ltd.
It is the intention of this privacy statement to explain to you the information practices of Secure Life Planning Ltd t/a Life Planning Ltd in relation to the information we collect about you.
For the purposes of the GDPR the Data Controller is:
Secure Life Planning Ltd t/a Life Planning Ltd
Address : 13 The Elms, Dunshaughlin, Co Meath
Phone: 086 8379491
Email: kellyanne@lifeplanning.ie
Kelly-Anne Quinn is responsible for Data Protection
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?
Secure Life Planning Ltd T/A Life Planning C515520 is regulated by the Central Bank of Ireland as an insurance intermediary registered under the European Union (Insurance Distribution) Regulations 2018 and as an Investment Intermediary authorised under the Investment Intermediaries Act, 1995. Copies of our regulatory authorisations are available on request. The Central Bank of Ireland holds registers of regulated firms. You may contact the Central Bank of Ireland on 1890 777 777 or alternatively visit their website at www.centralbank.ie to verify our credentials
Our principal business is to provide advice and arrange transactions on behalf of clients in relation to life, pensions and investment products, and to provide financial advice to clients on request. A full list of insurers, product producers and lending agencies with which we deal is available on request.
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Purpose for processing your data
Secure Life Planning Ltd t/a Life Planning Ltd may collect and hold the following personal Data through the process of an application, a Fact Find or a policy review. This information may be requested by us or could be offered by you voluntarily. It can include but is not limited to:
• data to identify you, your contact information i.e. name, address, telephone number(s), email address, gender, date of birth, occupation, PPS number, photographic identification, address verification, nationality; your financial details/financial circumstances as necessary i.e., employment, income, assets, liabilities, existing risk, pension and investment products held, bank account details (where applicable); your marital or civil status; other sensitive information e.g. medical information which you provide to us, where necessary for the service to be provided; information about you provided by others e.g. your spouse/partner, professional advisors, etc.; information which you have consented to us using; information provided when exercising your rights.
We process your data when
• It is necessary for a service or contract you have entered into e.g. when we provide you with a product recommendation / quote and you buy an insurance policy.
• There are legal or regulatory reasons e.g. where regulators require us to maintain records about our dealings with you.
• We have a legitimate interest to do so (and to which you may object). This means a business reason to use your data which takes into account your rights e.g. recording of phone calls for customer service reasons
If you contact us we will keep a record of that correspondence
Details of your visits to the website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources you access.
Typically, the legal basis for using your data is to provide a service or arrange a transaction which you have requested. The legal basis will also include complying with our legal and regulatory obligations, e.g. under our Central Bank authorizations, interaction with the Data Protection Commission, Financial Services and Pensions Ombudsman, Revenue, Pensions Authority, when conducting Anti-Money Laundering checks, law enforcement agencies.
Where you have agreed or explicitly consented to the using of your data in a specific way, you may withdraw your consent at any time. This can be done by emailing us at kellyanne@lifeplanning.ie or writing to us at 13 The Elms, Dunshaughlin, Co Meath.
We also use the non-personal data such as demographic information regarding, for example, user IP address where they have been clipped or anonymized, browser types and other anonymous statistical data involving the use of our website. We use this non-personal data to help design and organize our website.
We may provide non-personal data to third parties, where such information is combined with similar information of other users of the website e.g. we might inform third parties regarding the number of unique users visit our website, the demographic breakdown of other community users of our website, or the activities that visitors to our website engage in while on our website. The third parties to whom we may provide this information may include potential or actual advertisers, providers of advertising services (including websites tracking services), commercial partners, sponsors, licensees, researchers, and other similar parties.
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 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 Secure Life Planning Ltd t/a Life Planning 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:
• your authorized representatives;
• Doctors and healthcare professionals e.g. where needed for underwriting and claims
• IT service providers
• Legal advisors
• Reinsurers
• Statutory and regulatory bodies e.g. Central Bank of Ireland, Irish Revenue and law enforcement authorities
• product providers with which we propose to arrange business on your behalf;
• service providers who provide us with support services; eg IT Service Provider, Shredding Company
• statutory and regulatory bodies where we are legally obliged to do so;
• pension fund administrators, where applicable;
• pension scheme trustees or your employer in relation to the provision of pension benefits, where applicable.
• third parties with whom (i) we need to share your information to facilitate transactions or services you have requested, and (ii) you have agreed that we may share your information e.g Family members or friends, accountant, solicitor, executor or legal representative
You may be a customer of both Secure Life Planning Ltd t/a Life Planning Ltd and these third parties, and we and our partners may collect and share information about you detail. We are not responsible for third parties’ use of your personal data where such use is permitted for their own purposes. Please consult their privacy policies for further information.
Please see a list of the current agencies that we hold you can access their privacy notices on their websites:
Irish Life Assurance Company New Ireland Assurance
Zurich Life Assurance Standard Life
Omnibroker Cash Calc
Finance Ireland Credit Solutions DAC Royal London
Aviva
Secure Life Planning Ltd t/a Life Planning Ltd may make amendments to the above list in the future by adding or removing an agency from the above list.
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:
Secure Life Planning Ltd t/a Life Planning Ltd 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 Secure Life Planning Ltd t/a Life Planning 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. Secure Life Planning Ltd t/a Life Planning 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. Typically this is for 6 years after our relationship ends. However if you never take a contract with us or formally become a client we will destroy any data you gave to us 3 months after our last contact.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Secure Life Planning Ltd t/a Life Planning or how your complaint has been handled, you have the right to lodge a complaint directly with the Office of Data Protection. Contact Details are:
Office Data Protection, Canal House, Station Road, Portarlington, Co Laois, Ireland
Phone +353 (0761) 104 800 | LoCall 1890 25 22 31 | Fax +353 57 868 4757 | email info@dataprotection.ie
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. We may not be able to give you suitable advice and ongoing service
Cookie Information
Cookies are small pieces of information stored in simple text files, placed on your computer by a website. Cookies can be read by the website on your subsequent visits. The information stored in the cookie may relate to your browsing habits on the webpage, or a unique identification number so that the website can remember you on your return visit. Generally speaking, cookies do not contain personal information from which you can be identified, unless you’ve furnished such information to the website. You can change the settings on your internet browser to refuse all cookies if you wish.
We use cookies to collect information about visitors use of the website, including things like connection speed, operating system details, the time and duration of visits, and IP addresses. The information collected by cookies enables us to understand the use of our websites, including the number of visitors that we have, the pages viewed, time exposed to particular pages, etc. This in turn helps us to provide visitors with a better experience. We will not attempt to personally identify visitors from their IP addresses.
Cookies do not in any way compromise the security of your computer. Visitors can use most of our website with no loss of functionality if cookies are disabled from the web browser.
Analyst Tracking Software – Google Analytics
We may use Google Analytics, a service provided by Google, like many other websites. The cookies set by it gather anonymous data of how people are using this website and then provide us with visitor statistics, details of page views, etc., which enables us to provide better and more relevant content for visitors in the future. You can opt-out of Google Analytics by visiting the Google Ads Settings page on the Google website.
Profiling – automatic decision making
We may analyse your information using automated means:
• to help us understand your needs and develop our relationship with you;
• to help us to offer you products and service information we believe will be of interest to you, providing that you have given us consent to use your data for this purpose;
• by using product providers IT systems and similar systems where you apply for a financial product e.g. to obtain underwriting terms from an insurer, analyse your investment risk profile, affordability testing.
The types and sources of the information we process by automated means about you are listed under heading Purpose for Processing Data above. We also use automated processing to assist in compliance with our legal obligations in connection with prevention of money laundering, fraud and terrorist financing.
The results of the automated decision making may limit the products or services that we can provide to you. You can contest the decision based solely on automated decision making and require Secure Life Planning Ltd t/a Life Planning to exercise human intervention. Where you have any concerns, you are entitled to discuss them with a member of our staff.
The main categories of profiling and automatic decision making are
a) Risk profiling.
b) Profiling for marketing purposes.
c) Establishing affordability and providing quotations for financial services and mortgage product
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 at kellyanne@lifeplanning.ie
Privacy policy statement changes
Secure Life Planning Ltd t/a Life Planning 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.