Privacy Policy

Ken Roche Financial Services Ltd is connected with EasyLife4U.ie  as a Data Controller and complies with current General Data Protection Regulations.

Privacy Notice

 

Introduction

 

Ken Roche Financial Services is a limited company and 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.

 

For the purposes of the GDPR the data controller is:

  • Ken Roche Financial Services Ltd
  • 16 Cromwellsfort Drive, Mulgannon, Wexford
  • When we refer to ‘we’ it is Ken Roche Financial Services 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?

 

Ken Roche Financial Services is a limited company that provides a financial advisory service to its clients. We act as a brokerage and in finding financial solutions for our clients we represent our clients when processing business for them.

 

Our Data Protection Officer / GDPR Owner and data protection representative can be contacted directly here:

 

  • Ken Roche
  • info@kenrochefinancialservices.com
  • 0872430229

 

How do we collect your information and what information do we collect?

The personal information we collect varies depending upon the nature of our services. We will endeavour to provide you with an overview of those categories of personal data our organisation collects and our purpose for using that data.

 

Our organisation collects personal data in the following ways, if you:

 

  • request a service from us; for example you wish to set up Life Assurance or a Pension
  • register with or use any of our websites or online applications; www.easylife4u.ie
  • engage with us on social media; for example you message our facebook page.
  • contact us with a complaint or query;

 

What information do we collect?

The information we collect about you includes the following:

 

1. Contact and Identifying information, e.g., name, address, contact details; email, mobile, landline
2. Unique identifiers e.g.

  • PPS number – the reason why we collect your PPS number is to link your product to revenue for approval, for example your pension product
  • pension scheme reference number- the reason why we collect this is that your scheme is approved by the Pension Authority and the Revenue.
  •  insurance policy numbers, the reason why we collect this is to match your policy with any claims or enquiries.
3. Demographic details, age, gender, (check if you do collect) marital status, lifestyle, and insurance requirements; date of birth, dependents, photo ID, as well as collecting personal information about you, we may also use personal information about other people, for example family members you wish to insure on a policy. E.g., your children/spouse

And to ensure we collect all the relevant information required to complete an application.

4. Family and Beneficiary Data, e.g., dependants, next of kin or nominated beneficiaries, Power of Attorney, Enduring Power of Attorney. Details of Solicitor/Tax Advisor/Accountant.
5. Employment information e.g., role, employment status (such as full/part time, contract), salary information, employment benefits, and employment history;

This information is necessary for our Fact Find with our clients.

6. Health information such as information about your health status, medical records and medical assessment outcomes; We collect medical information relating to personal habits (e.g., smoking and consumption of alcohol), medical history. We may also process certain special categories of information, for example information about your personal characteristics (biometric information) or disability information.
7. Pensions and Insurance Benefits information such as current benefits, pension entitlement information, date of retirement and any relevant matters impacting your benefits such as voluntary contributions, or a PAO.
8. Financial details e.g., bank account details, salary, tax code, third-party deductions, benefits and entitlement data, national insurance contributions details.
9. Claims Data (From you and any relevant third parties).
10. Marketing preferences: we will only send you direct marketing if you explicitly consent. These can be for information and not purely marketing reasons and you can always opt out.

 

 

When our organisation collects sensitive personal data as defined within the GDPR we will ensure that we require this information, and we have your explicit consent and/or authorisation prior to our collection. Please see the further information contained in this Privacy Notice that outlines special categories of personal data.

 

Information we could but don’t automatically collect.

We do not automatically collect certain types of information when you visit our websites and through e-mails when we communicate with you. We do not use automated technologies to include the use of web server logs to collect IP addresses, “cookies” and web beacons. If we ever do we’ll place a notice on our website and update this section of our policy.

How do we use your personal data?

Your Personal Data will be used to enable us to fulfil our contractual obligations in relation to your request for insurance, investment, protection, pension products, financial advice, quotes.

 

1. Performing services for our clients and prospective clients – when you require insurance/investment products, we use your data to enable us to provide the required product
2. Statutory and other regulatory requirements – we are required to carry out various obligations which include:

  • AML
  • Knowing your customer “Fact Find”
  • Adherence to the Consumer Protection Code

 

3. Communicate and marketing to youAgain as above, we only block email you with information you may find relevant. You will always have to option to opt out.
4. Process claims.
5. To contact you if required or to respond to any communications that you might send to us.
7. Carry out our obligations arising from any contracts entered between you and your product provider and to provide you with the information, products and services that you request.
10 Handling complaints.
11 To notify you about changes to our service.
 

 

Legal Basis

We need to ensure that we process your personal data lawfully. We rely on the following legal grounds to collect and use your personal data.

 

Performance of a contract When we assist you in entering a contract with a provider, we will collect and use your personal data to enable us to fulfil that service.
Legal obligation The use of some of your personal data is necessary for us to meet our legal obligations e.g., pension contributions for Revenue Certificates, Regulatory purposes to the Central Bank.
Consent Sometimes we may rely on consent as a legal basis for processing your information. For example, we rely on consent to collect and use personal data for any criminal convictions or alleged offences.  This is used when we need to assess risk relating to an insurance policy for you. We share this information with other third parties where it is necessary to manage these services provided to you – these services include insurance underwriters, reinsurer and other insurance providers.

 

We may also rely on your consent to send direct marketing to you. We will ensure that we present this to you concisely.  We will also ensure that we use clear and plain language and if you give us your consent you can withdraw this easily at any time.

 

Sometimes if you refuse to provide information that we reasonably require to provide the services, we may be unable to offer you the services and/or we may terminate the services provided with immediate effect.

If you require further information on any of the above basis for processing your data, we can provide you with further details.

 

How we share your data

When required, we may make your information available to third parties with whom we have a relationship, where that third party is providing services on our behalf. We will only provide those third parties (data processors) with information that is necessary for them to perform the services.  We will take measures to protect your information, such as putting in place Standard Contractual Clauses and confidentiality agreements.

 

Insurance Partners where we need to manage the services provided to you such as Product Providers and insurance underwriters and reinsurers. You can refer to their privacy statements on their website for more information about their privacy practices.
Public authorities, regulators and government bodies, where necessary for us to comply with our legal and regulatory obligations, or in connection with an investigation of suspected or actual illegal activity.
On the sale or reorganisation of our business whether by asset or share disposal or other transaction relating to our business.

 

 

Transferring personal data outside of Ireland

We currently do not share data with entities outside of Ireland.

 

Security

The security of your personal data is important to us, we have implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk.  We have processes in place to protect your personal data from loss, unauthorised access, misuse, alteration and destruction.

 

Retention

Ken Roche Financial Services Ltd shall not keep personal data in a form that permits identification of data subjects for a longer period than is necessary.

Ken Roche Financial Services Ltd may store data for longer periods if the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the implementation of appropriate technical and organisational measures to safeguard the rights and freedoms of the data subject.

 

The retention period for each category of personal data will be set out in our Retention Schedule along with the criteria used to determine this period, including any statutory obligations we have. Should you require further information we would be happy to provide.

 

Personal data will be disposed of securely.

 

Data Subjects Rights:

Ken Roche Financial Services Ltd will facilitate your 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. (The erasure of such data will be dependent on our other legal obligations, and whether the data is subject of legal privilege).
  • 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 make a complaint: if we refuse your request under rights of access, we will provide you with a reason as to why.

All 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.

 

Complaints

If you wish to make a complaint about how your personal data is being processed by Ken Roche Financial Services Ltd or how your complaint has been handled, you have the right to lodge a complaint with our Data Protection Officer.

 

You may also lodge a complaint with the Data Protection Commission (DPC) in Ireland, whose details are:

 

Data Protection Commission

21 Fitzwilliam Square South,

Dublin 2.

D02RD28

Web: www.dataprotection.ie

Email: info@dataprotection.ie

 

See website for updated contact details to reach the appropriate section within the DPC.

 

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.

 

Special Categories of personal data

Special categories of data are sensitive in relation to your fundamental rights and freedoms and therefore require specific protection when processed as these could create significant risks to the rights and freedoms of individuals.

 

If we collect any special categories of personal data, such as health data, we will either obtain your explicit consent or we will adhere to the Data Protection Act 2018. This Act allows us to process special categories of personal data for insurance and pension purposes. We will ensure we have suitable and specific measures in place to safeguard the rights and freedoms of you and the processing of your data. These measures relate to the below:

  • a policy of insurance or life assurance,
  • a policy of health insurance or health related insurance
  • an occupational pension, a retirement annuity contract or any other pension arrangement
  • the mortgaging of a property

Contact Us

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 0872430229 or info@kenrochefinancialservices.com.