The Independent Mortgage Centre DAC t/a IMC 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 IMC in relation to the information we collect about you.
For the purposes of the GDPR the data controller is: John Reynolds.
Contact details of John Reynolds are 021 4273334 and email@example.com .
When we refer to ‘we’ it is IMC.
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? IMC are Financial and Mortgage Brokers. We are based in 77 South Mall, Cork. We provide Financial and Mortgage advice to our clients.
Purpose for processing your data
Why we are processing your data? In order for us to provide you with Financial and /or Mortgage advice IMC needs to collect personal data for the provision of services.
Our reason (lawful reason) for processing your data under the GDPR is:
IMC needs to process your data as this is necessary in relation to a contract of insurance to which you have entered into or because the individual has asked for something to be done so they can enter into a contract. IMC 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 IMC use the personal data it collects about me?
From the 25th May 2018,we will comply with both the EU General Data Protection Regulation and Irish Data Protection legislation and only collect, utilise and share personal data in strict adherence with those Data Protection laws and principles. IMC 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 endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary.
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 that we will obtain your explicit consent.
Who are we sharing your data with? We share your data with Life Insurance companies in the case of Life Insurance, Pensions and Investments products and banks in the case of mortgages.
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 IMC refuses your request under rights of access, we will provide you with a reason as to why.
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. IMC 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.
In the event that you wish to make a complaint about how your personal data is being processed by IMC or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and IMC’s data protection representative Mr John Reynolds.
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
Profiling. Financial and mortgage advisors using profiling in their business. The main categories are:
- a) 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.
- b) Profiling for marketing purposes. When we seek to contact you about other services,
- c) Establishing affordability and providing quotations for financial services and mortgage product.
Additional Processing 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.
Our Data Protection Supervisory Authority:
You can contact the Irish Data Protection Commissioner office at:
Telephone: 076 1104800 Low Call: 1890252231 Fax: 057 868 47457
Post: Canal House, Station Road, Portarlington, Co Laois. R32 AP23
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 021 4273334 or email at: firstname.lastname@example.org