Rose Private Privacy Statement
Here at Rose Private we take your privacy seriously and will only use your personal information to administer your account and to provide the products and services you have requested from us.
This document is being provided to you in line with our obligations under the General Data Protection Regulation (GDPR) which will come into force on the 25 May 2018. Please take time to read this notice carefully. If you are under 16 years of age, please read this summary with a parent or guardian and ensure you understand it. If you have any questions about how we use your information, please contact us at the details given at the end of this document.
1. Who we are.
Rose Private is a boutique advisory firm that provides professional financial planning services to clients and their families. We provide advice and arrange transactions on behalf of clients in relation to life/pension/investment and protection products/policies/tax and estate planning.
Our GDPR owner and data protection representative can be contacted here:
Phone number 015310220
2. The Information we hold about you
The personal data we collect from you such as your name, address, financial details and potentially sensitive information are necessary to provide you with our financial planning services. These include but are not limited to negotiating, maintaining or renewing insurances and handling insurance claims and providing advice and arranging transactions on behalf of clients in relation to life/pensions/investments and protection products /policies and tax and estate planning.
At times, the provision of our services may necessitate the transfer/disclosure of your personal data by Rose Private to insurers, product providers, partners, agents, regulators and professional advisers.
We will hold
- Data to identify you, including your contact information
- Your financial details/ financial circumstances
- Your marital status
- Information which you have consented to give us
- Other personal information such as Anti Money Laundering information, telephone recordings, CCTV images and information provided by you when exercising your rights under section 10 below.
3. When we collect your information
We collect information
- You give us
- Information from your use of our products and services
- Information provided to us by third parties
4. How we use your information and legal basis
We use and share your data where:
- You have agreed or explicitly consented to the using of your data in a specific way (you may withdraw consent at any time)
- Use is necessary in relation to a service or a contract that you have entered into or because you have asked for something to be done so that you can enter into a contract with us or one of our partners.
- Use is necessary because we have to comply with a legal obligation e.g. reporting to the Central Bank and regulatory authorities.
5. How we use automated processing
We may analyse your information using automated means to
- Profile your risk - To establish your attitude to investment risk (relates to pensions and investments) Rose Private uses certain software tools which calculate your attitude to risk having answered a series of questions.
- Anti-Money laundering rules – Databases are used to ensure that AML legislation is being followed
- Profiling for marketing purposes - When we seek to contact you about other services, as outlined above we run automated queries on our database to establish the suitability of proposed products or services to your needs.
- Establishing affordability and providing quotations for financial services products.
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.
6. Who we are sharing your information with
We may pass your personal data on to third-party service providers contracted to Rose Private 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 Rose Privates 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 party insurers/product providers that we may pass your personal data to are in Appendix 1.
We have issued all our third party processors with a Data Processor checklist asking them GDPR specific questions
7. How long we hold your data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained.Rose Private will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body (Central Bank of Ireland) and our internal governance.
8. Implications of not providing your data
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.
9. Using companies to process your information outside the European Economic Area (EEA)
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.
10. How to exercise your information rights including the right to object
Rose Private 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 judicial review: in the event that Rose Private refuses your request under rights of access, we will provide you with a reason as to why.
- Right to object to automated processing, including profiling.
- Right to withdraw consent: in the event that processing is based on consent you may withdraw consent at any time.
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.
In the event that you wish to exercise your data rights or make a complaint about how your personal data is being processed by Rose Private or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Rose Privates GDPR Owner at the email address given above. If we are unable to deal with your request fully within a calendar month, we may extend this period by a further two calendar months and explain the reason why. If you make your request electronically, we will try to provide you with the relevant information electronically.
11. How to contact us with data protection issues
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on (01)5310020 or email Dataprotection@roseprivate.ie
List of Financial Institutions that may receive your personal data from Rose private.
Aviva Life & Pensions Ireland and Friends First
Standard Life International DAC
New Ireland Assurance Company plc
Zurich Life Assurance plc
Royal London Insurance DAC
Quilter Cheviot Europe Limited
Independent Trustee Company Ltd
Harvest Financial Services Ltd
Merrion Stockbrokers Limited
Appian Asset Management
Cantor Fitzgerald Ireland Limited
Wealth Options Limited
Quintas Wealth Management Limited