Nelson Life Privacy Notice.

Introduction.

This Privacy Notice applies to all personal information processing activities carried out by Nelson Life.

Nelson Life is a data controller in respect of personal information that we process in connection with our business and that includes the products and services that we provide to you. In this notice, references to “we”, “us” or “our” are references to Nelson Life.

Nelson Life 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 Nelson Life in relation to the information we collect about you.

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.

How to contact us:

For the purposes of the GDPR the data controller / Data Protection Officer / GDPR Owner :

  • Address | Head of Data Protection, Nelson Life, Dockgate, Dock Road, Galway, Ireland.
  • Email | dataprotection@nelsonlife.ie
  • Phone number | 091 44 11 88.

Who are we?

Our principal address is Nelson Life, Dockgate, Dock Road, Galway, Ireland.

For more information on Nelson Life, please visit About Nelson Life today.

Purpose for processing your data.

As a client of Nelson Life we process personal information about you and we do this for a number of specific reasons, primarily:

  • For the purpose of providing the agreed level of service to you under your contract with an employee of Nelson Life;
  • In order to comply with statutory obligations and other tax and regulatory requirements which we are subject to (for example anti-money laundering requirements); and
  • In order to provide you with information in relation to Nelson Life products and services.

Please be aware that we will never disclose your personal information to any third party unless you have consented to it, where it is necessary to enable us to carry out our contractual obligations to you or where we are obliged to in order to comply with legal, statutory and/or regulatory requirements. You should know that we will not sell your personal information to any third party to be used for marketing purposes

Why we are processing your data? Our legal basis.

In order for us to provide you with the products and services outlined in our Terms of Business, Nelson Life need to collect personal data. Our reason (lawful reason) for processing your data under the GDPR is:

Legal basis – Nelson Life needs to process your data as this is necessary in relation to a contract of insurance to which the individual has entered into or because the individual has asked for something to be done so they can enter into a contract.

In any event, Nelson Life 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 Nelson Life use the personal data it collects about me?

Nelson Life 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.

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 below.

Subject to suitable and specific measures being taken to safeguard the fundamental rights and freedoms of data subjects, the processing of data concerning health shall be lawful where the processing is necessary and proportionate for the purposes of the following:

(a) a policy of insurance or life assurance,

(b) a policy of health insurance or health-related insurance,

(c) an occupational pension, a retirement annuity contract or any other pension arrangement, or

(d) the mortgaging of property

Who are we sharing your data with?

We may pass your personal data on to third-party product providers and service providers contracted to Nelson Life in the course of advising you – for example, our specified CRM provider and product providers (outlined in our Terms of Business document). Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to full fill the service they provide on your behalf.

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: Our third party CRM provider and product providers. 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.

Nelson Life 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 Organisation Name 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. Nelson Life will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body the 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 Nelson Life or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Nelson Life’s data protection representatives Data Protection Officer / GDPR Owner.

Failure to provide further information.

If we are collecting your data for a contract or service 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.

Financial and mortgage advisors using profiling in their business.  The main categories are:

  • 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.
  • 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 needs.
  • Profiling for marketing purposes. Establishing affordability and providing quotations for financial services products.

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.

Privacy policy statement changes.

Nelson Life 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.

This privacy policy was last reviewed 23 May 2018.