Privacy Statement

Introduction

 

Orla Murray Financial Services is committed to protecting and respecting your privacy.  We wish to be transparent on how we process your data.  It is the intention of this privacy statement to explain to you the information practices of Orla Murray Financial Services in relation to the information we collect about you.

 

This document is being provided to you in line with our obligations under the General Data Protection Regulation (GDPR), which came into force on 25 May 2018.  From that date, the GDPR, together with applicable Irish requirements, amended existing data protection law and placed enhanced accountability and transparency obligations on organisations when using your information.  The GDPR introduced changes which 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.

 

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.  If you have any questions about how we use your information, please contact us at the details below.

 

1. Who we are

 

Throughout this document, “we”, “us’, “our” and “ours’ refer to Orla Murray Financial Services.   Your information is held by Orla Murray Financial Services.

 

2. The information we collect about you

 

We will hold:

• Data to identify you, including your contact information
• Your financial details/financial circumstances
• Your marital status
• Your financial associations
• Information about you provided by others e.g. joint policy applications
• Information which you have consented to us using; and
• Other personal information such as: CCTV images at our office

 

Sometimes we may use your information even though you are not our customer. For example, you may be a beneficiary, director, or representative of a customer of ours or be a potential customer applying for a product or service via us.

 

3. When we collect your information

 

We collect information:

• You give us
• Information from your use your products arranged via us
• Information provided to us by third parties.

 

4. Purpose for processing your data

 

The information that you provide (‘data’) will be used for the administration of any existing business you hold through us, or to administer any enquiries or future services as requested by you.  We may share your data with our agents and service providers in order to provide an efficient service to our clients.

 

Our reason for processing your data under the GDPR is:

• Consent – You have given consent to process your data for one or more specific purpose
• Contract – The processing of data is essential to service and monitor existing business, or because you have asked for something to be done
• Legal basis – We may need to process your data as this is necessary in relation to a contract to which you have entered into or because you have asked for something to be done so you can enter into a contract
• Vital Interests – It is necessary to protect your vital interests in exceptional circumstances
• Legitimate Interests – such as conducting marketing activities or training and strategic planning

 

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.  Data is at all times treated as confidential and the appropriate measures are taken to ensure it is secure. Orla Murray Financial Services is subject to the requirements of the Data Protection Acts 1988-2003 and will hold your data in accordance with all applicable data protection laws and principles.

 

5. How will Orla Murray Financial Services use the personal data it collects?

 

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 endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.

 

6. 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 obtain your explicit consent

 

7. Who we are sharing your data with

 

We may pass your personal data on to third-party service providers contracted to Orla Murray 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 Data Protection Laws.

 

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:

• Authorised representatives
• Third parties with whom:
  • we need to share your information to facilitate transactions you have requested, and
  • you ask us to share your information
• Service providers who provide us with support services
• Statutory and regulatory bodies (including central and local government) and law enforcement authorities
• Third parties in connection with a sale or purchase of assets being arranged
• Pension fund administrators, trustees of collective investment undertakings and pensions trustees insurers/re-insurers, insurance bureaus;

 

We will ensure all third party processors we use are GDPR compliant.

 

8. Data Subjects Rights:

 

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 Organisation Name refuses your request under rights of access, we will provide you with a reason as to why.

 

If you wish to exercise any of your data rights, you can contact us at www.orlamurray.com/contact, in-our office, by mail to Orla Murray Financial Services, 1 Forthill Street, Off Merchants Road, Galway, or by contacting 091 564 777.

 

9. Retention of your personal 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 The Central Bank of Ireland and our internal governance.

 

 

 

 

10. Complaints

 

In the event that you wish to make a complaint about how your personal data is being processed by Orla Murray Financial Services, or how your complaint has been handled, you have the right to lodge a complaint directly to the Data Protection Commission or another supervisory authority. You can contact the Office of the Data Protection Commissioner at: Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231 Fax: +353 57 868 4757 E-mail: info@dataprotection.ie Postal Address: Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois.

 

11. Failure to provide further information

 

If you do not wish to provide us with your information we may not be able to:

• Provide requested products and services to you
• Efficiently review suitability of existing products and services held
• Provide new products / renew existing products held
• Make a sound financial recommendation

 

12. Profiling – automatic decision making

 

We may use automatic decision making tools for the following purposes:

• Risk profiling – to establish your attitude and capacity for risk
• Establishing affordability and providing quotations for financial services and mortgage products

 

13. 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.

 

14. How to Contact Us

 

If you have any comments or questions regarding this statement, please contact us on 091 564 777 or reception@orlamurray.com

 

15. Privacy policy statement changes

 

Orla Murray Financial Services may change this Privacy Statement from time to time.  When such a change is made, we will post a revised version on our website.  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