LHW Financial Planning Ltd is committed to protecting and respecting your privacy.
For the purposes of the GDPR the data controller is:
- LHW Financial Planning Ltd
- Tel – +353 1 2710130
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?
LHW Financial Planning Ltd provides an financial planning service within a client relationship that is based on trust and care. This is based on over 40 years’ experience in the financial planning sector. We help clients to achieve their financial goals. To do this, we listen to, and understand what is really important both personally and financially. We then develop a plan which provides financial peace of mind without the fear of running out of money.
Our GDPR Owner and data protection representatives can be contacted directly here:
- Roisin Kane
- + 353 1 2710192
Purpose for processing your data
Gathering personal information is mandatory in order to ensure we provide you with the most suitable financial and/or risk products.
Depending on circumstances we can also ask you for an expenditure outline. This would be the case for a more detailed financial plan.
Our service largely considers the implications of a financial journey. There are issues such as providing for income if you live beyond what is deemed a retiring age, to the consequences of death/illness on both your personal and business lives. The follow on may be the passing of wealth to the next generation.
Once we gather the information, we provide you with a planning report which sets out a pathway of financial travel. This could include provisions for families/businesses in the event of death or illness and also a plan surrounding asset accumulation. At all times you will be made aware as to why we are using this personal data.
This includes the provision for medical information which is treated as highly sensitive information.
Why do LHW Financial Planning Ltd need to collect and store personal data?
In order provide you with a financial planning service we need to collect personal data to ensure we can provide the best advice possible at all times. In any event, we 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.
In terms of being contacted for marketing purposes LHW Financial Planning Ltd would contact you for additional consent.
How will LHW Financial Planning Ltd use the personal data it collects about me?
LHW Financial Planning Ltd 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.
LHW Financial Planning Ltd is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will LHW Financial Planning Ltd contact me?
LHW will only ask questions that are important and relevant to the service we provide. Access to your information is carefully controlled.
Why we are processing your data? Our legal basis.
LHW Financial Planning Ltd is regulated by the Central Bank of Ireland as an intermediary firm. We report on an annual basis to them to ensure we remain under the umbrella of the Central Bank as a financial advisory firm.
In order for us to provide the most appropriate advice we have to obtain a picture of your finances. This is the reason for the fact find. Once obtained, we analyse the information. We then provide a report which assesses the exposures that may exist from both a personal and corporate point of view. In order to provide the optimum advice, we need as much information as possible to ensure the service is the best it can be.
One of the following grounds must be satisfied in order for us to process your personal data:-
- Consent – Consent of the data subject (See below for conditions for valid consent);
- Contract – Necessary for the performance of the contract (or in the case of Brokers to provide the insurance product);
- Legal Obligation – Necessary to comply with a legal obligation;
- Vital Interests – Necessary to protect the vital interests of the data subject;
- Public Interest – Necessary for the performance of a task in the public interest or in the exercise of an official authority – included for completeness but not applicable to Brokers; or
- Legitimate Interests – Necessary for the legitimate interests of the data controller, unless such interests are overridden by the interests of the data subject (See requirements below); and
- In the case of Criminal History/ongoing criminal proceedings only: Risk Assessment or Fraud Prevention. Note: Criminal history is no longer deemed Sensitive (or Special Category) data.
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 the below
- we will obtain your explicit consent
- ensure the personal data is necessary for employment rights or obligations;
- protect the vital interests of the data subject, including the protection of rights and freedoms;
- necessary for the legitimate activities with appropriate safeguards;
- personal data made public by the data subject;
- legal claims;
- substantial public interest;
- preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, provision of health or social care treatment, or management of health and social care systems and services, under the basis that appropriate contracts with health professionals and safeguards are in place;
- public health, ensuring appropriate safeguards are in place for the protection of rights and freedoms of the data subject, or professional secrecy;
- national laws in terms of processing genetic, biometric or health data.
Who are we sharing your data with?
Fact find, and reporting is held by us for our purposes only. Following the report orders for contracts may be agreed and information will pass to relevant financial product providers. We may also need to share some of your other personal information such as bank details, salary and health information to relevant parties. This information is often required in order to set up suitable financial products.
We may pass your personal data on to third-party service providers contracted to LHW Financial Planning Ltd 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 are obliged to dispose of your details in line with data protection /GDPR legislation. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise
If we transfer personal data to a third party, 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:
We, LHW Financial Planning Ltd facilitate the data subject’s rights in line with the 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.
- 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 LHW Financial Planning Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.
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.
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. LHW Financial Planning Ltd will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body, Central Bank, Revenue and our internal governance.
Profiling – automatic decision making
LHW may use your personal data for profiling purposes in order to allow us to group our clients based on certain common characteristics. As an example, clients over 60 years of age for whom we provide pension advisory services may receive communications from LHW on topics which we feel will be of interest to them as they approach retirement. One such topic would be the management of investment risk.
If we have received your personal data from another source:
The GDPR Owner is responsible for ensuring that the privacy statement is correct and that mechanisms exist such as having the Privacy Statement on LHW Financial Planning Ltd’s website to make all data subjects aware of the contents of this notice prior LHW Financial Planning Ltd commencing collection of their data.
All staff that need to collect personal data are required to follow this procedure.
Questions Regarding the Privacy Statement and Conditions of Use
If you have any questions about our Privacy Statement and Conditions of Use, please contact us by e-mail at firstname.lastname@example.org
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.