Privacy Statement
Introduction
At PSRA, we are committed to protecting and respecting your privacy. We strive to be transparent about how we process your data and to demonstrate our accountability under GDPR, ensuring you understand your rights as a client.
This privacy statement aims to explain PSRA's information practices regarding the data we collect about you.
For the purposes of the GDPR the data controller is:
Evan Hughes
Email: info@expertadvice.ie
Phone: 019055504
When we refer to ‘we’ it is PSRA.
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?
Evan Hughes trading as PSRA is regulated by the Central Bank of Ireland as an Insurance Intermediary registered under the European Union (Insurance Distribution) Regulations 2018, as an Investment Intermediary authorised under the Investment Intermediaries Act, 1995 and, as a Mortgage Credit Intermediary under the European Union (Consumer Mortgage Credit Agreements) Regulations 2016.
Our Services
Our primary business is providing expert advice and facilitating transactions for clients regarding life, pensions and investment products. We work with a comprehensive range of insurers and product providers, and a full list of our partners is available upon request.
As an authorised advisor, we provide comprehensive, market-wide advice and can arrange business with life assurance companies with whom we hold an agency. PSRA offers advice and products across a range of areas, including life cover, serious illness cover, income protection, savings, investments, and pensions.
We are here to assist you with any queries related to your policies or claims during the policy term. We will also explain the various restrictions, conditions, and exclusions that may apply. However, it is your responsibility to thoroughly review the policy documents, literature, and brochures to ensure you fully understand the nature of the policy coverage, particularly in relation to Permanent Health Insurance (PHI) and serious illness policies.
Our GDPR owner and data protection representative can be contacted directly here:
Evan Hughes
Email: info@expertadvice.ie
Phone: 019055504
Purpose for processing your data
You may provide us with personal data and special categories of personal data in the following ways:
- By corresponding with us in writing, by phone, email, or other methods. We ask that you disclose only the necessary personal data and/or special categories of personal data required to deliver our products and services, or to submit a question, suggestion, or comment regarding our websites, products, or customer service.
- By applying for or taking out one or more products through us, whether as a policyholder or a life insured.
- By corresponding with us in relation to one or more of your policies (e.g., regarding a claim).
- By posting on our social media platforms, message boards, blogs, or any other services where you can share information. Please note that any personal data or special categories of personal data shared through these services may become public information.
- When supplying us with goods or services.
- By applying to work with us. The information you may provide includes your CV, cover letter, name, address, email address, and phone number. CVs should include relevant details of your employment history and education (e.g., degrees obtained, places worked, positions held, and any awards). We request that you refrain from including special categories of personal data (e.g., nationality, gender, height, weight, medical information, religion, philosophical or political beliefs) or financial data in your application.
For all products, we collect the following categories of personal data:
- Contact details: Name, address, email address, and telephone number.
- Identification details: Gender, marital status, and date of birth.
- Occupation details
- PPS (Personal Public Service) number
- Nationality and country of residence
- Photographic identification: Required for anti-money laundering checks.
- Bank details, debit/credit card information (where applicable).
- Income details (where applicable).
- PEP (Politically Exposed Person) status: To comply with anti-money laundering regulations.
In some cases, we may also receive sensitive information from which your trade union membership, religious, or political beliefs can be inferred (e.g., if you are part of a group scheme through a professional, trade, religious, community, or political organization).
Additional data for specific products:
Pension Products
- Income details
- Employer name and address (for executive and group schemes)
- Disability information: If applying for early retirement on the grounds of ill health (special category data)
Investment Products: To comply with Revenue laws, we collect:
- US citizen status
- Tax Identification Numbers from other countries (if applicable)
Protection Products:
- Income details
If your product includes insurance (e.g., protection, as well as certain pension and investment products with life or serious illness benefits), we also collect the following special categories of personal data:
- Medical history: This may include personal and relevant family medical history, personal habits (e.g., smoking and alcohol consumption), and prescription information.
Why are we processing your data? Our legal basis
In order to provide you with pensions advice, financial advice, financial planning, or financial products, PSRA is required to collect personal data. Our lawful basis for processing your data under the General Data Protection Regulation (GDPR) is as follows:
PSRA processes your personal data as necessary for the following purposes:
- Contractual necessity: To facilitate the performance of a contract, such as an insurance or product contract that you have entered into, or to take steps at your request prior to entering into such a contract.
- Financial advice and planning: To provide financial advice and/or a financial plan, based on the consent you have provided.
- Pensions advice: To offer pensions advice, with your explicit consent.
- Ancillary services: To deliver additional services, such as acting as your tax agent, where we have received your consent.
- Internal marketing purposes: With valid consent, we use your data for marketing activities to offer you suitable products or services and to improve our internal processes.
- Statistical analysis: Data is anonymised and analysed to help PSRA better understand customer needs and to develop products and services tailored to those needs.
In all instances, PSRA is committed to ensuring that the personal data we collect, and process is appropriate for its intended purpose and does not infringe on your privacy.
How will PSRA use the personal data it collects about me?
PSRA will process (collect, store, and use) the information you provide in full compliance with the EU's General Data Protection Regulation (GDPR). We are committed to ensuring that your information is accurate, kept up to date, and retained only for as long as necessary to fulfil its purpose.
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 obtain your explicit consent prior to processing any such data.
Who are we sharing your data with?
We may share your personal data with third-party service providers contracted by PSRA as part of our service to you. Any third parties we engage are obligated to keep your information secure and to use it solely for the purpose of fulfilling the services they provide on your behalf. When they no longer require your data for these services, they will dispose of it in accordance with PSRA procedures.
If we need to share your sensitive personal data with a third party, we will only do so after obtaining your explicit consent, unless legally required to disclose it otherwise.
Third Parties We May Share Your Data With:
- Product Providers: A list of these providers is available upon request by contacting PSRA at 019055504 or info@expertadvice.ie. Your data will only be shared with product providers that you have consented to, enabling them to provide and maintain your product.
- Technical Suppliers: We may share your data with technical suppliers necessary for storing, organizing, and transmitting your data to support the provision and maintenance of the requested product or service. Your data will be transferred securely and will not be used for any other purpose.
- Revenue Authorities: If you have chosen PSRA to act as your tax agent for products eligible for tax relief.
- Professional Service Providers: We may engage other professional service providers when legally required to facilitate a specific product for you. In such cases, we will inform you of the details when necessary.
- Your Representatives: We will share your data with authorized representatives only when we have received your explicit authorization.
- Regulatory Bodies: We may disclose your data to regulators and official agencies as required by law, regulation, or legal process.
- Employers: If a group policy is in place, we may share your data to facilitate premium payments or claims processing.
Safeguards and Data Transfers
PSRA is committed to ensuring appropriate safeguards are in place when transferring personal data to third parties or outside the EU. As the data controller, we ensure that recipients (processors or other controllers) provide adequate safeguards, ensuring enforceable data subject rights and effective legal remedies.
We also utilize cookies on our website to track visitor activity and enhance the visitor experience. Please note that we do not collect personal information through cookies and cannot identify individuals from this data. However, we do collect personal information from visitors who complete our contact form, which we use to respond to queries.
Data Subjects Rights
PSRA facilitates your rights as our clients in accordance with our data protection policy and the subject access request procedure. This information is available upon request.
Your rights as a data subject
At any point while we possess or process your personal data, you, as the data subject, have the following rights:
- Right of Access: You have the right to request a copy of the information we hold about you.
- Right of Rectification: You have the right to correct any inaccurate or incomplete data that we hold about you.
- Right to Be Forgotten: In certain circumstances, you can request the erasure of your data from our records.
- Right to Restriction of Processing: Under specific conditions, you have the right to restrict the processing of your personal data.
- Right of Portability: You have the right to request the transfer of your data to another organization.
- Right to Object: You have the right to object to certain types of processing, including direct marketing.
- Right to Object to Automated Processing, Including Profiling: You have the right to not be subject to the legal effects of automated processing or profiling.
- Right to Judicial Review: If PSRA refuses your request under the right of access, we will provide you with the reason for our decision.
All requests related to these rights will be forwarded to any third parties involved in the processing of your personal data, as indicated in our procedures.
We are committed to ensuring transparency and fairness in our processing of your data and will provide additional information as needed.
Retention of your personal data
Data will not be retained for longer than necessary for the purposes for which it was collected. PSRA will process personal data in accordance with our retention schedule, which is governed by our regulatory body, the Central Bank of Ireland, as well as our internal governance policies.
Complaints
If you wish to make a complaint about how your personal data is being processed by PSRA or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority, as well as with PSRA's Data Protection Representative (GDPR Owner).
Failure to provide further information
If we are collecting your data for a contract and you are unable to provide this information, it may result in the inability to complete the contract or may lead to inaccuracies in the contract details.
Profiling – automatic decision making
Risk Profiling
To establish a customer's attitude toward investment risk (related to pensions and investments), our advisors use automated calculators that assess responses to a series of questions. You have the right to object to this profiling; however, please be aware that doing so may prevent PSRA from recommending the most suitable funds or products for your savings, investment, and pension needs.
Profiling for marketing purposes
When we seek to contact you about other services, we conduct automated queries on our computerised database to assess the suitability of proposed products or services for your needs. You can opt out of this process at any time.
Establishing affordability and providing quotations for financial services products
You have the right to object to this profiling; however, doing so may prevent us from completing a contract or recommending the most suitable product for your situation. You may also request human intervention to contest and make representations regarding any such decision.
Additional Processing
If we intend to further process your personal data for a purpose other than that for which it was originally collected, we will provide you with this information prior to the processing.
Contact Us
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us at 01 905 5504 or via email at info@expertadvice.ie.
Privacy policy statement changes
PSRA may update this privacy policy from time to time. When changes are made, we will post a revised version online. These changes will take effect immediately upon posting. It is your responsibility to review this privacy policy periodically to stay informed about any updates. By using our services, you agree to the terms of this privacy policy.
This privacy policy was last reviewed in October 2024