Clearview as a data controller
Clearview Investments & Pensions Limited “Clearview” is a financial services advisor and broker that provides personalised financial planning services in Ireland. We are committed to protecting the privacy of personal data under our control and this statement summarises our approach. While providing personal data to us in the course of business or while using our website, we will manage your data in accordance with GDPR and Irish law.
This is a summary document to provide information on our processing activities and to inform you of your rights. Please refer to the “full” Privacy Notice when considering your rights. For more information please contact our Data Protection Representative on 061 633777, or e-mail firstname.lastname@example.org
- THE PERSONAL DATA THAT WE PROCESS AND WHY
Client engagement information
Purpose: We obtain personal data from you to manage your relationship with Clearview, to provide financial planning services and fulfil our legal obligations. This may include identification, financial details, taxation, bank details and security data
Legal basis for processing: we may rely upon our agreement with you, the legitimate interest of Clearview*, our obligations under law, the vital interest of the client or consent as a basis for processing your personal data.
Investment, Pension or Protection (insurance) products
Purpose: We may obtain your personal data from, or provide your personal data to, a financial product provider on foot of a letter of authority or an instruction from you respectively. Where we provide data to a provider, it is normally to get a quotation, or to fulfil a financial planning instruction from you. This may include identification, taxation, income, bank details, and details relating to third parties such as spouse or another beneficiary. Where a third-party personal data is involved, we will ask you to warrant that data provided to us has been obtained lawfully and that subject rights have been observed.
Legal basis for processing: we may rely upon our agreement with you, a written instruction from you, the legitimate interest of Clearview*, our obligations under law, or consent as a basis for processing your personal data to evaluate or facilitate a contract with a financial services product provider.
Purpose: We are required in law to provide your personal data to certain state bodies or appointed persons. These may include: Revenue, our regulators (the Central Bank of Ireland), data relating to AML, CAB, an order of court, other agencies or regulated individuals (e.g. Auditors or an MLRO).
Legal basis for processing: we will rely upon our obligations under law as a basis for the processing of data for this purpose.
* to provide financial planning services under Irish law and regulated by the consumer protection code and the Central Bank of Ireland and to administer the organisation in an efficient manner
- TRANSFERRING YOUR DATA TO A THIRD PARTY
There are many activities of Clearview that require your data to be transferred to a third party. They may include the following categories of recipients: Revenue, a state regulator or individuals appointed to maintain regulatory compliance, other state agencies that we are obliged in law to provide data, auditors, financial product providers, credit agencies, Insurance providers, professional advisors, IT and support providers, and electronic payment organisations.
In any event, personal data shall only be transferred for specific purposes that are in the legitimate interest of the business, are subject to a contract with you, or are required by law. We may also transfer your personal data upon your instruction or with your consent.
- WHERE YOU HAVE PROVIDED CONSENT
Where we are processing data based on your consent you may withdraw that consent at any time.
- INTERNATIONAL TRANSFER
Clearview does not currently transfer personal data to any recipients outside of the EEA European Economic Area unless such transfer is of a Client’s data or data provided by the Client, and upon that Client’s request.
- INFORMATION RELATING TO CHILDREN AND VULNERABLE PERSONS
The processing of personal data relating to minors receives special attention under Data Protection Regulation and we shall treat this information with particular care. Children are defined as under 16’s in Ireland. Information obtained about children shall comply with the requirement for parental consent and shall receive additional consideration while planning an operational process.
- SPECIAL (SENSITIVE) DATA
Clearview recognises special categories of data, specifically personal data revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, genetic or biometric data, or a subject’s health or sexual life. The processing of these categories of information shall typically require consent. Health details may be required for the purpose of insurance.
- YOUR RIGHTS
In addition to the right to know the information on this data protection statement, subjects also have the right to:
- Information on whether we have Personal Data relating to a subject, the categories of data and the purpose of processing.
- Access your personal data. Where the format is not reasonably understood, this shall be delivered in an intelligible format.
- Have inaccurate, incomplete, or out-of-date personal data that we hold about you corrected or deleted.
- Withdraw consent for your personal data to be processes – where it was obtained from you on the basis of consent.
- Be informed if a failure to provide the personal data will have any direct and material personal consequences.
- Make a submission on any automated decisions making processes or profiling of you.
- Transfer your data to another controller.
- Have your personal data excluded from certain categories of processing.
- Lodge a complaint with the Data Protection Commissioner. Contact details for the DPC can be found at www.dataprotection.ie.
– There are some limitations to these rights.
– You can contact us to exercise these rights by e-mail at email@example.com
– Clearview will require proof of your identity prior to discussing or providing access to your personal data
- DATA RETENTION
We retain personal data that you submit to us only for as long as is necessary for the purposes for which it was obtained, or as required by law. Clearview reserves the right to delete personal data prior to the conclusion of the retention period.
|Storage of personal data –|
|Purpose of processing||Duration||Criteria for the storage of personal data|
|Client information||7 years||From when we ‘ceased to provide any product or service’ to the client.|
|Identity verification data||3 years||Upon expiry of use (it has been replaced)|
|Client questionnaire (financial profile) – Where engagement does not proceed||3 months||From cessation of engagement|
|Client questionnaire (financial profile)||7 years||From when we ‘ceased to provide any product or service’ to the client, or greater where regulation mandates.|
|Instruction, contract or agreement for a financial product||7 years||From when we ‘ceased to provide any product or service’ to the client.|
|Supporting documents for an instruction contract or agreement for a financial product||7 years||From when the ‘particular transaction is discontinued or completed’|
|Incidents or complaint reports||Permanent|
|Documentation relating to revenue||Stored as mandated by law plus 12 months|
|AML and Fraud prevention documentation||Stored as mandated by law plus 12 months|
|Records and explanation of transactions, and of the provision of service||As mandated by the Central Bank of Ireland or other lawful regulatory authorities, plus 12 months|
|Nothing in this section confers an obligation upon Clearview to retain personal data on behalf of Subjects.|
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Last Updated: May 2020