M G Anderson Insurances Ltd 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 Breffní Anderson, our contact details are 1 & 2 Windsor Terrace, Dun Laoghaire, Co Dublin Tel: 01 2140 726 email email@example.com.
When we refer to we/us, we mean M G Anderson Insurances Ltd.
Please read this Privacy Notice 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?
We are a General, Life and Investment Insurance Broker who are committed to working diligently on behalf of our customers to provide the best service and cover to suit our customers individual insurance requirements.
Our Data Protection Officer, GDPR Owner. can be contacted directly here:
- Name Breffní Anderson
- Email address firstname.lastname@example.org
- Phone number 01 2140 726
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 any insurance requirement you might have.
- register with or use any of our websites or online applications requesting quotations, etc.
- use our website/apps and it may install cookies or other tracking technologies onto your device.
- contact us with a complaint or query.
- enquire of a service by phone as incoming calls are recorded and a notice to that effect is provided.
What information do we collect?
The information we collect about you includes the following:
|1.||Contact and Identifying information, e.g., your name, address, contact details; email, mobile, landline|
|2.||Unique identifiers e.g.
· PPS number – the reason why we collect your PPS number is for Central Bank compliance and ID requirements
· pension scheme reference number- the reason why we collect this is for ease of tracing assets funding in compliance with Revenue regulations
· insurance policy numbers, the reason why we collect is for the efficiency of advice
|3.||Demographic details, age, gender, 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 in relation to good advice.|
|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.||Publicly available sources: e.g., Information about you in the public domain such as Director information from the Companies Registration Office.|
|7.||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, this information relates to Life & Income assurance products.|
|8.||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, in order to assist with good advice|
|9.||Financial details e.g., bank account details, details of your credit history and bankruptcy status, salary, tax code, bonus payments, benefits and entitlement data, national insurance contributions details.|
|10.||Claims Data (From you and any relevant third parties), i.e. where you have been injured by a third party.|
|11.||Marketing preferences: we will only send you direct marketing if you explicitly consent. We will correspond with you in relation to your value statements to keep you informed and updated in relation to your investment accounts you may hold via our office, or sudden changes in your insurance risk or terms. We will when you contact our office ask you if it is in order to send you marketing information or updates on investment opportunities.|
|13.||Criminal records information e.g., the existence of or alleged criminal offences, or confirmation of clean criminal records for motor products. We only collect what is relevant to the policy you are applying for.|
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 automatically collect.
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, independent 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/Sanction checking
· Knowing your customer “Fact Find”
· Adherence to the Consumer Protection Code
|3.||Communicate and marketing to you – by telephone, email or post|
|4.||Process claims – we will see data in relation to the subject matter of the claim in order to provide information to the insurer claims department in a timely manner.|
|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 us and to provide you with the information, products and services that you request.|
|8.||Arranging premium finance agreements, with Insurance Providers /Close Brothers Premium Finance Ireland.|
|9.||Provide professional services in relation to wealth management.|
|10||Handling complaints the data controller is Breffní Anderson, contact details are 1 & 2 Windsor Terrace, Dun Laoghaire, Co Dublin Tel: 01 2140 726 email: email@example.com.|
|11||To notify you about changes to our service by telephone, email or post|
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 enter a contract with you, 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 i.e. pension contributions for Revenue Certificates, regulatory purposes for the Central Bank and ID requirements.|
|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.
|Legitimate interests||Where we rely on this legal basis to collect and use your personal information, we shall take appropriate steps to ensure the processing does not infringe the rights and freedoms conferred to you under the applicable data privacy laws.|
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. You dated is protected by encryption and is password protected.
|1.||Insurance Partners where we need to manage the services provided to you such as Product Providers and insurance underwriters, reinsurers, and loss adjuster. You can refer to their privacy statements on their website for more information about their privacy practices related to proposals, claim forms or additional driver forms.|
|2.||Legal advisers, loss adjusters, and claims investigators, where necessary to investigate, exercise or defend legal claims, insurance claims or other claims of a similar nature.|
|3.||Medical professionals, e.g., where you provide health information in connection with a claim against your insurance policy; or when we are providing a quote for insurance i.e. Life Assurance and Income Protection Proposal Forms.|
|4.||EU Law enforcement bodies, when required to do so by law and/or regulation, or another legal request, i.e. any form of request made by a compliance authority.|
|5.||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.|
|6.||Third-party processors: We outsource our processing operations to suppliers that process personal information on our behalf. Examples include IT service providers who manage our IT and back-office systems and telecommunications networks, and accounting and payroll providers, CRM providers, to include Open GI and Applied Systems. These processing operations remain under our control and we have data processing agreements in place with all our third-party processors to ensure all processing is carried out in accordance with our security standards and the GDPR.|
|7.||Internal and external auditors where necessary for the conduct of Company, Revenue or Insurance Company audits or a complaint or security threat.|
|8.||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 share data with Lloyd’s Underwriters located in the UK. The EU Commission adopted adequacy decisions for transfers of personal data to the UK. This means that the EU accepts that the UK data protection regime is substantially equivalent to the EU regime and allows personal data to be transferred freely from the EEA to the UK. Therefore, the UK is not deemed a third country.
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.
M G Anderson Insurances Ltd shall not keep personal data in a form that permits identification of data subjects for a longer period than is necessary.
M G Anderson Insurances 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.
Personal data will be disposed of securely.
For general brokers only; liability insurance
If you hold insurance against a liability that may be incurred by you against a third party, where for whatever reason you cannot be found or you become insolvent, or the court finds it just and equitable to so order, then your rights under the contract will be transferred to and vest in the third party even though they are not a party to the contract of insurance. The third party has a right to recover from the insurer the amount of any loss suffered by them. Where the third party reasonably believes that you as policyholder have incurred a liability the third party will be entitled to seek and obtain information from the insurer or from any other person, who is able to provide it including M G Anderson Insurances Ltd concerning:
- the existence of the insurance contract,
- who the insurer is,
- the terms of the contract, and
- whether the insurer has informed the insured person that the insurer intends to refuse liability under the contract.
Data Subjects Rights:
M G Anderson Insurances Ltd will facilitate your rights in line with our Data Protection Policy and the subject access request procedure. This is available on request.
- 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.
If you wish to make a complaint about how your personal data is being processed by M G Anderson Insurances Ltd or how your complaint has been handled, you have the right to lodge a complaint with our Data Protection Officer Breffní Anderson.
You may also lodge a complaint with the Data Protection Commission (DPC) in Ireland, whose details
Data Protection Commission
21 Fitzwilliam Square South,
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.
When you fail to provide us with information we require to fulfil our obligations to you, we may be unable to offer our services to you.
Profiling – automatic decision making.
An automated decision is when we input your personal data into a computer programme and this programme analyses your personal data to provide us with a result. There is no human involvement in the decision making. i.e. automated home, life, private motor insurance quotations, establishing affordability, quality of cover, and providing quotations for financial services products via software engines. If a decision is taken by automated means, you have the right to object to this and ask us to reconsider the service you have asked us to provide. Some further examples of automated decisions that we undertake are listed below.
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 in relation to life or income insurance 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,
- an occupational pension, a retirement annuity contract or any other pension arrangement
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 01-1240 726 or firstname.lastname@example.org.
Privacy notice/ statement changes
When we update this Privacy Notice/Statement, we will post a revised version online. Changes will be effective from the point at which they are posted. We would encourage you to review our Privacy Notice so that you are aware of updates.
Please also reference our terms and conditions.