GOGAN INSURANCES LTD t/a GOGANS PRIVACY STATEMENT
Gogan Insurances Ltd hereafter shown as Gogans are 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 Gogans in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
NAME: Gogan Insurances Ltd t/a Gogans
ADDRESS: Unit A5 Nutgrove Office Park, Rathfarnham, Dublin 14
When we refer to ‘we’ it is Gogans
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?
Gogans are a General and Financial Services Broker. Our principal business is to provide advice and arrange transactions on behalf of clients in relation to Life and Pensions and General Insurance products.
Our Data Protection Officer/GDPR Owner and data protection representative(s) can be contacted directly as follows:
Name: Elaine Teeling Email: firstname.lastname@example.org Tel: 01 299 0 299
Purpose for processing your data
We will hold data:
- Data to identify you
- Your financial details and financial circumstances on application form including but not limited to medical information
- Your marital status
- Your financial associations
- Information about you provided by others eg joint policy or investment applications
- Information that you have consented to us being used
- Other personal information such as criminal conviction data ; telephone recordings or accounts on same and information provided when exercising your rights as a data subject
- Notes on details you have provided us by phone or in person
Sometimes we may use your information even though you are not a client of ours. For example you may be a beneficiary, guarantor, director, cardholder or representative of a client of ours or a potential client applying for one of our products or services.
We collect information:
- You give us
- Information from use of our products, services or website
- Information provided to us by Third Parties
Why we are processing your data? Our legal basis.
In order for us to provide you with a service or contract you have eg to provide you with insurance services when you take out a policy or because you have asked for something to be done so that you can enter into a contract with us ie you have asked us for advice or a quote when you apply to us for insurance. Gogans need to collect personal data for the above service. Our reason (lawful reason) for processing your data under the GDPR is:
- Legal basis – Gogans 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.
In any event, Gogans 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 Gogans use the personal data it collects about me?
Gogans 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 Gogans 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 Gogans 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:
- Your authorised representatives
- Third Parties with whom (1) we need to share your information to facilitate transactions you have requested, and (2) you ask us to share information
- Service Providers who provide us with support services
- Statutory and regulatory bodies (including central and local government) and law enforcement authorities
- Third parties in connection with the sale or purchase of investment assets by us: persons making an enquiry or complaint, advice agencies and other regulated intermediaries, receivers, liquidators, examiners, official assignee for bankruptcy and equivalent in other jurisdictions including court orders
- Trade associations and professional bodies, non-statutory bodies and members of trade associations
- Pension fund administrators, trustees of collective investment undertakings and pension trustees, insurers and product producers
- Healthcare professionals and medical consultants
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:
Gogans 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 Gogans 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. Gogans will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body Central Bank of Ireland and our internal governance.
Implications of not providing your data
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.
- Provide requested products or services to you
- To continue to provide and /or renew existing products or services
- Assess suitability for product service requirements
How we use automated processing or “analytics”
We may analyse your information using automated means to
- Help us understand your needs and develop our relationship with you
- To help us offer your products and service information we believe will be of interest to you 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 need
- To make assessments /recommendations where you apply for a Financial Product
We also use automated processing to assist in compliance with our legal obligations in connection with prevention of money laundering, fraud and terrorist financing for example to screen for suspicious transactions
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.
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on (01) 299 0 299 or email email@example.com
In the event that you wish to make a complaint about how your personal data is being processed by Gogans or how your complaint has been handled, you have the right to lodge a complaint directly with Gogans or the Data Protection Commission, Canal House, Station Road, Portarlington, Co. Laois firstname.lastname@example.org or 076 1104800 or lo call 1890 252 231
We record all telephone calls and all follow up calls for verification and training purposes.