Introduction
Moore Financial Consultants 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 Moore Financial Consultants in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
- Michael Moore
- Contact details of Moore Financial Consultants 058 86009
- When we refer to ‘we’ it is Moore Financial Consultants
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 we are
We are a personalised and relationship focused business whose goal is to provide a full on-going financial planning service. Our aim is to protect and grow the wealth of our clients through careful financial planning tailored to their specific needs. Moore Financial Consultants is a member of Brokers Ireland (BI). As a member of BI we must be in a position to place insurance with at least five insurers of the relevant form (life/non-life) and therefore can generally give consumers greater choice than agents and tied agents.
Our principal business is to provide advice and arrange transactions on behalf of clients in relation to life & pensions and investment products. A full list of insurers, product producers and lending agencies with which we deal is available on request.
Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:
- Michael Moore (Michael @moore.ie). Tel 058 86009
Purpose for processing your data
- We will be using your data to submit applications to Life, Investment and Mortgage providers. We will use your data to prepare and assess investment, pension and protection options on your behalf.
- Your information will be stored on our CRM system which is data protected and scanned files and associated documents are stored using Microsoft Office 365 Sharepoint.
- Your data is only sent on to Third parties that you have agreed to do business with. Your data will not be passed onto anyone without your permission.
Our organisation collects personal data in the following ways, if you:
- request a service from us by completing our financial or mortgage fact find
- register with or use any of our websites or online applications such as our mortgage application system through Money advice.
- use our website/apps and it installs cookies or other tracking technologies onto your device.
- engage with us on social media through Linkedin.
- contact us with a complaint or query;
- apply for a position with us.
What information do we collect?
The information we collect about you includes the following:
- Contact and Identifying information, e.g., name, address, contact details; email, mobile, landline
- Unique identifiers e.g.
- PPS number – the reason why we collect your PPS number is that some life companies request this information to set up pensions.
- pension scheme reference number- the reason why we collect this is that it may be needed to check what other benefits you might have.
- insurance policy numbers, the reason why we collect this is if you are transferring existing schemes over to us.
- 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
- Family and Beneficiary Data, e.g., dependents, next of kin or nominated beneficiaries, Power of Attorney, Enduring Power of Attorney. Details of Solicitor/Tax Advisor/Accountant
- 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. - Publicly available sources: e.g., Information about you in the public domain such as Director information from the Companies Registration Office.
- 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 is required for life and protection policies.
- 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, PAO.
- Financial details e.g., bank account details, details of your credit history and bankruptcy status, salary, tax code, third-party deductions, bonus payments, benefits and entitlement data, national insurance contributions details,
- Claims Data (From you and any relevant third parties). We may have to get details of any pensions you are claiming from or any protection policies you are benefiting from.
- Marketing preferences: we will only send you direct marketing if you explicitly consent. We will send up relevant market updates about your specific policies and the market as is deemed relevant.
- Online information: e.g., information about your visits to our websites.
- Events information e.g., information about your interest in and attendance at our events, including provision of feedback forms.
- Social media information (e.g., likes and posts) with our social media presence; this includes LinkedIn.
- Searches that we undertake in relation to sanctions, money laundering and credit checks. We may on occasion carry out a PEP check if we deem it necessary.
- Calculators on our website. We use this data to perform calculations to prepare quotations for life insurance or mortgages.
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.
We sometimes automatically collect certain types of information when you visit our websites and through e-mails when we communicate with you. Automated technologies may include the use of web server logs to collect IP addresses, “cookies” and web beacons. Other cookies such as functional cookies, marketing cookies and analytical cookies will only be used with your expressed consent. Further information about our use of cookies can be found in our Cookie Notice at the footer of our web page. www.moore.ie
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.
- 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
- 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
- Communicate and marketing to you – we will send you an annual review of the investment policies you hold with us and will send you additional market updates as we think relevant through out the year. These will be emailed or posted out to you.
- Process claims – If you need to be contacted in relation to making a claim, medical information may be needed from your doctor. In as far as is possible we do not deal directly with doctors this is done through the life companies.
- To contact you if required or to respond to any communications that you might send to us.
- 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.
- Handling complaints
- To notify you about changes to our service
Legal Basis
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 e.g., pension contributions for Revenue Certificates, Regulatory purposes to the Central Bank. |
| 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. |
If you require further information on any of the above basis for processing your data, we can provide you with further details.
How will Moore Financial Consultants use the personal data it collects about me?
Moore Financial Consultants 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.
What happens if information is given by one partner on another partner who is not at the meeting
It is assumed that if one party gives the name and date of birth and contact details of the other party that they have the permission of the other party to do so. If one party signs a fact find on behalf of both it is assumed that they have the expressed consent of the other party to do so. The personal information of the party not present at the meeting will not be used for marketing purposes.
If information is requested on policies in joint names?
If one of the policy holders only makes a subject request e.g. the husband of a married couple, then you can only provide him with personal data relating to himself and not his wife.
If both parties make a subject access request together i.e. in the one letter, you can provide all personal data relating to both of them in one response, i.e. you can take it that they consent to the other receiving personal data about them.
Who are we sharing your data with?
We will only ever share your information with a third party that you have given us your permission to contract with on your behalf. We will not pass your data to any third party outside of the EU.
We may pass your personal data on to third-party service providers contracted to Moore Financial Consultants 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 fulfill 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 their data 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: Any of the companies that we have listed in our Terms of Business. If we are required to send data to anyone outside of this list we will let you know in advance.
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:
Moore Financial Consultants 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 Moore Financial Consultants 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. Moore Financial Consultants 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.
If you have transacted with us and hold a policy through our agency we are obliged to retain your data for 6 years. If you provide us with your data but you do not take a policy with us we will delete all the information we hold on you within 12 months.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Moore Financial Consultants or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Moore Financial Consultants ’s data protection representatives Data Protection Officer / GDPR Owner
Policy on Data Breech’s
If there is a data breech or the risk of a data breech, we will contact the Data protection Commissioner and follow the process as is outlined by them.
Failure to provide further information
If we are collecting your data for any given 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
Financial and mortgage advisors using profiling in their business. 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 (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. - Establishing affordability and providing quotations for financial services products.
In order to assess your affordability for a mortgage or other such products we will have to input your data into affordability calculators.
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.
- 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.
- Vetting and risk management agencies such as credit reference, criminal record, fraud prevention, data validation and other professional advisory agencies, where necessary to prevent and detect fraud in the insurance industry and take steps to assess the risk in relation to prospective or existing insurance policies and/or the services.
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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;
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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.
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EU Law enforcement bodies, when required to do so by law and/or regulation, or another legal request.
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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;
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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.
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. -
Internal and external auditors where necessary for the conduct of company audits or to investigate a complaint or security threat.
Security
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.
Complaints
If you wish to make a complaint about how your personal data is being processed by Moore Financial Consultants or how your complaint has been handled, you have the right to lodge a complaint with our Data Protection Officer.
You may also lodge a complaint with the Data Protection Commission (DPC) in Ireland, whose details are:
Data Protection Commission
21 Fitzwilliam Square South,
Dublin 2.
D02RD28
Web: www.dataprotection.ie
Email: info@dataprotection.ie
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.
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 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,
- a policy of health insurance or health related insurance
- an occupational pension, a retirement annuity contract or any other pension arrangement
- the mortgaging of a property
Contact Us
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 058 86009
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.
This privacy policy was last reviewed in Jan 2022 Ver (i)