Privacy Policy

Introduction

Hartnett Dalton Financial Services Limited 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 Hartnett Dalton Financial Services Limited in relation to the information we collect about you.

For the purposes of the GDPR the data controller is:

• Christina Hartnett Dalton
• Contact details of Christina Hartnett Dalton of Hartnett Dalton Financial Services Limited t/a HD Financial Services; email chris@hdfs.ie; phone 0878576561; website www.hdfs.ie
• When we refer to ‘we’ it is Hartnett Dalton Financial Services Limited

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?

Christina Hartnett Dalton is the Director of Hartnett Dalton Financial Services Limited t/a HD Financial Services.  Christina has a wealth of financial services expertise, and will provide clear, concise advice in all aspects of financial planning. Christina has worked in the Financial Services sector since 1994. Christina is a Qualified Financial Advisor and Fellow of the LIA, her qualifications also include Wealth Management (Dip), and Professional Certificate in General Insurance.  Services provided are; Financial Advice to include Life and Serious Illness cover, Income Protection, Retirement Planning, Business Protection, Employee Benefits, Investments and Savings, Inheritance tax planning and Mortgages.

Our Data Protection Officer / GDPR Owner and data protection representative can be contacted directly here:

• Name: Christina Hartnett Dalton
• Email Address: chris@hdfs.ie
• Phone Number: 091 638 630 and 087 857 6561

Purpose for processing your data. Why we are processing your data? Our legal basis.

In order for us to provide with financial planning advice Hartnett Dalton Financial Services need to collect personal data for the provision of Life, Serious Illness and Income Protection, Retirement Planning, Business Protection, Employee Benefits, Investments and Savings, Inheritance Tax Planning and Mortgages. Our reason (lawful reason) for processing your data under the GDPR is:

• Legal basis – Hartnett Dalton Financial Services Limited needs to process your data as this is necessary in relation to a contract of insurance to which the individual has entered into or because the individual has asked for something to be done so they can enter into a contract of Life, Serious Illness and Income Protection, Retirement Planning, Business Protection, Employee Benefits, Investments and Savings, Inheritance Tax Planning and Mortgages.

In any event, Hartnett Dalton Financial Services Limited 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 HDFS Limited use the personal data it collects about me?

Hartnett Dalton Financial Services Limited 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.

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

Who are we sharing your data with?

We may pass your personal data on to third-party service providers contracted to Hartnett Dalton Financial Services Limited 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 fulfil 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 Hartnett Dalton Financial Services Limited 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:

Hartnett Dalton Financial Services Limited to

• Aviva Life and pensions
• Friends First Life Assurance Co. Ltd.
• Irish Life
• New Ireland
• Royal London
• Standard Life
• Zurich Life
• BCP Asset Management
• Blackbee Investments
• Broker Solutions
• Cantor Fitzgerald
• Greenman Investments
• Wealth Options
• Omnibroker CRM Systems

We have issued all our third-party processors with a Data Processor checklist asking them GDPR specific questions. 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

Hartnett Dalton Financial Services Limited 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 Hartnett Dalton Financial Services Limited 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.

Retention of your personal data

Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Hartnett Dalton Financial Services Limited 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.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Hartnett Dalton Financial Services Limited or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Hartnett Dalton Financial Services Limited data protection representatives Data Protection Officer / GDPR Owner – Christina Hartnett Dalton.

Failure to provide further information

If we are collecting your data for a protection, savings/investment, retirement, mortgage 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 – automatic decision making Profiling;

Financial and mortgage advisors using profiling in their business. The main categories are
a) Risk profiling.
b) Profiling for marketing purposes.
c) Establishing affordability and providing quotations for financial services and mortgage product

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, as outlined above * we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.

a) Establishing affordability and providing quotations for financial services products.

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.

Contact Us

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact Christina Hartnett Dalton on 091 638 630 or 0878576561, by email chris@hdfs.ie.

Privacy policy statement changes

Hartnett Dalton Financial Services Limited may change this privacy policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically so you’re aware of any changes. By using our services you agree to this privacy policy.

This privacy policy was last reviewed in May 2018