Privacy Statement – Summit Life & Pensions Ltd T/A Summit Financial Planning
Summit Financial 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.
It is the intention of this privacy statement to explain to you the information practices of Summit Financial Planning in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
- Summit Life & Pensions Ltd T/A Summit Financial Planning (CRO 523148)
- Summit Life & Pensions Ltd T/A Summit Financial Planning’s contact details are as follows:
- Email: firstname.lastname@example.org
- Tel: 01-4445282
- When we refer to ‘we’ it is Summit Financial Planning
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?
Summit Financial Planning is a Dublin based brokerage and is regulated by the Central Bank of Ireland. Our registered address is 13 Upper Pembroke Street, Dublin 2. We are focused on providing quality financial advice to our clients and offer advice on a range of different financial products. The main categories of financial products we provide advice on are as follows:
- Pension Products
- Protection Products
- Investment & Savings Products
In addition to this, Summit Financial Planning also provide a Financial Planning Service where we analyse in depth your current financial position and how to augment it going forward.
We at Summit Financial Planning respect your right to privacy and comply with our obligations under the General Data Protection Regulation 2016.
By visiting this website, you are accepting the terms of this Privacy Statement. Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of these other websites. Different terms and conditions may apply to such websites, and such websites may not maintain the same standards of privacy as this website.
Our GDPR Owner and data protection representatives can be contacted directly here:
- Ian Feighery (Director)
- Email: Ian@summitlife.ie
- Tel: 01-4445282
Purpose for processing your data
We will process any Personal Data you provide to us for the following purposes:
- To provide you with information about financial products in the market and/or about the services offered by Summit Life Financial Planning
- To process on-line application forms submitted to us for the purposes of providing financial products. Any applications submitted online or by e-mail will be subject to the same terms and conditions as those completed by hand in paper form including additional terms and conditions relating to credit reference checking, money laundering and regulatory notices.
- To contact you if required in connection with your account or enquiry and to respond to any communications you might send us.
- Managing our relationship with you (for example, updating you on changes to our business or updating your record with us if you change your address etc.)
- Responding to any complaints you might have
In order for us to provide our clients with a comprehensive Summit Financial Planning service, we collect personal data from the client:
This is the data that identifies you as a natural person (data subject); or can be used to identify or contact you and may include your name, address, telephone numbers, e-mail addresses, online identifier and date of birth or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Special types of personal data include revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data, for the purpose of, uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
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:
- We will obtain your explicit consent
What do we consider Data Processing?
We consider any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means or not, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction as data processing.
Disclosure of Information to Third Parties:
We will not disclose your Personal Data to third parties unless you have consented to this disclosure or unless the third party is required in order to process an application or other communication from you or to perform the services that you have applied for. We will however disclose your Personal Data if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other statutory requirement.
Why we are processing your data? Our legal basis.
In order for us to provide you with Financial Advice, Summit Financial Planning needs to collect personal data for one, or all, of the following:
- the establishment of your Financial Position
- the creation of your personalised Financial Plan
- the provision of Financial Advice
- the recommendation of financial product(s)
Our reason (lawful reason) for processing your data under the GDPR is:
- Legal basis – Summit Financial Planning 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, Summit Financial Planning 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 Summit Financial Planning use the personal data it collects about me?
Summit Financial Planning 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.
Who are we sharing your data with?
We may pass your personal data on to third-party service providers contracted to Summit Financial 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 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 Summit Financial Planning 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:
- Life Insurance Companies
- Trustee Companies
- Fund Managers
- Client Management System Providers
- Financial Planning Software Providers
- Fund Analytics Software 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:
Summit Financial Planning 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 Summit Financial Planning 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. Summit Financial Planning will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory bodies which includes; The Central Bank of Ireland, the Office of the Financial Services and Pensions Ombudsman, the Competition and Consumer Protection Commission and our internal governance.
In the event that you wish to make a complaint about how your personal data is being processed by Summit Financial Planning or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Summit Financial Planning data protection representatives and GDPR Owner, Ian Feighery.
- Email: Ian@summitlife.ie
- Tel: 01-4445282
- Summit Life & Pensions, 13 Upper Pembroke Street, Dublin 2
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.
Profiling – automatic decision making
Summit Financial Planning consider any form of automated processing of personal data intended to evaluate certain personal aspects relating to a natural person, or to analyse or predict that person’s performance at work, economic situation, location, health, personal preferences, reliability, or behaviour as data profiling.
You as the data subject may object to profiling and a right to be informed about the existence of profiling, of measures based on profiling and the envisaged effects of profiling on the individual.
The main categories are
- Risk profiling.
- Profiling for marketing purposes.
- Establishing affordability and providing quotations for financial services and mortgage product
- Risk Profiling
To establish a customer’s attitude to investment risk (relating to pensions, investments & savings) Summit Financial Planning uses a third party automated calculator which calculates the client’s attitude to various levels of risk having answered a series of questions following a short questionnaire.
- Profiling for marketing purposes
When we seek to contact you about other services, as outlined above, we analyse our client data on our Segmentation System in order to establish the suitability of proposed products or services to your needs.
- Establishing affordability and providing quotations for financial services products
In order to determine which product provider is most suitable for your Financial needs, Summit Life and Pension Ltd will run searches across providers which use your personalised data.
Sale of Business:
We reserve the right to transfer information (including your Personal Data) to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of Summit Financial Planning provided that the third party agrees to adhere to the terms of this Privacy Statement and provided that the third party only uses your Personal Data for the purposes that you provided it to us. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-out.
Your Personal Data is held on secure servers hosted by our Internet Service Provider and Client Management System. We take our responsibilities in relation to the security of your Personal Data very seriously. The nature of the internet is such that we cannot guarantee or warrant the security of any information you transmit to us over the internet. No data transmission over the internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your Personal Data and we will review these measures regularly.
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.
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 01-4445282 or email email@example.com