Data Protection & Privacy Notice
Effective Date 25th May 2018
Progressive Financial Services is committed to protecting and respecting your privacy. We wish to be transparent about how we process your data and show 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 Progressive Financial Services in relation to the information we collect about you.
Our GDPR owner and data protection representative can be contacted directly here:
- Name: Leah Pittam
- Email: firstname.lastname@example.org
- Phone: 01 901 5582
When we refer to ‘we’ or ‘us’, we are referring to Progressive Financial Services. Please read this Statement carefully as it sets out how any personal data we collect from you or that you provide to us will be processed by us.
Who are we?
Progressive Financial Services provides financial advice and arranges financial products and services for individuals and businesses. Its advisors go through a ‘fact finding’ process to ensure they are providing the best advice. The aim is to help individuals and business alike visualise their financial future, set objectives and create a concise plan to achieve the same. We also help optimise income and utilise tax efficiencies.
What information we gather
When we collect information about you in person or over the phone, we intend to tell you why we are asking for the information and what we intend to do with it. We collect information (often referred to as ‘Fact Finding’) which is then used to provide financial advice and quotes. The categories of data include contact details, name, date of birth, address, income and expenses, assets and liabilities, detail of dependents, spouse/partners and general financial behaviours.
We also collect information while completing application forms in order to arrange the product or service required. This may include health information which is required by the product provider and is only kept by Progressive Financial Services for a reasonable amount of time to meet your product needs
From time to time, you may visit our website without identifying yourself or revealing any personal information. Progressive Financial Services may collect domain information from your visit, such as the date and time of your access, the pages you have accessed, the name of the Internet Service Provider, the Internet Protocol (IP) address by which you are accessing the Internet, and the Internet address from which you linked to our site, if applicable. We use this information to better understand how our website is being used so that we can improve its performance and your experience.
Some forms on our website may request that you give us information about yourself from which we are able to identify you, such as your name, email or other address. Some of the ways in which we may collect information from you are listed below and all of which do not happen automatically, but you must voluntarily ‘Opt In’ or request the data.
- Subscription to newsletters or other Progressive Financial Services content-related correspondence
- Enquiry form
- Event registrations for seminars, conferences, etc.
- Other downloads
The information we collect about you or your computer is used to run the website, respond to your requests or process any transactions you have requested. It may also be used to verify your identity, send you information or contact you in relation to a product or service that you are using or that we believe may be of interest to you after you have chosen to Opt in.
Data collected from our website will not be held for longer than is necessary, credit card transactions will be held for the duration of the transaction and general client details will be held while you are a customer.
Our legal basis for processing your data
For us to provide you with financial advice we need to collect personal data to understand your personal circumstances and do a needs analysis. Personal details are also required to quote on financial products and services.
In order to enter into a contract with any of the product providers Progressive Financial Services deals with it is necessary to process your data.
Progressive Financial Services 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 Progressive Financial Services use the personal data it collects about me?
Progressive Financial Services will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We endeavour to keep your information accurate and up to date and not keep it for longer than is necessary.
Progressive Financial Services’ legitimate interest is to provide clients with comprehensive financial advice and clear plan to meet their objectives. This involves looking at their overall data including personal financial situation, including existing provisions, dependents and goals.
Special Categories of personal data
If we collect any special categories of personal data such as health, religious beliefs, racial, ethnic origin we will ensure we obtain your explicit consent.
Who are we sharing your data with?
In certain instances we may make your information available to third parties providing the contract for a product, or who hold information about you that we are trying to retrieve as part of the Fact Finding process. We will only provide those third parties with information that is necessary for them to perform the search and we take measures to protect your information. Any third parties that we may share your data with are obliged to keep your details securely, and use them only to fulfil the service as requested. When they no longer need your data they will dispose of it in line with with their own Data Protection procedures.
The information we collect may be used, stored and processed in the EU, the UK and any other countries Progressive Financial Services does business with or requires information from. If we transfer personal data to a third party outside the EU, we as the data controller will ensure the recipient (processor or controller) has the appropriate safeguards in place. 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.
An up to date list of the third parties that we hold agency with is available upon request. We also hold all our third-party processors GDPR specific procedures on file.
Progressive Financial Services’ intent is to strictly protect your personal information, honour your choice for its intended use and carefully protect your data from loss, misuse, unauthorised access or disclosure, alteration or destruction. We have taken appropriate measures to safeguard and secure information we collect, including the use of encryption on company computers and the use of secure third-party technology providers. Specific details of these technology providers and the security measures they have in place against cyber hacks are available upon request.
However, you should always take into consideration that the internet is an open forum and that data may flow across networks with little or no security measures and therefore such information may be accessed by people other than those you intended to access it.
How to update your personal information
You are entitled to know whether we hold information about you and if we do (subject to certain limitations), to have access to that information and have it corrected if it is inaccurate or out of date. To exercise your Right of Access or to update your details under your Right of Rectification or Erasure please email your request to the contact address below with proof of identity.
Your rights as a data subject
Progressive Financial Services facilitates our client’s rights in line with our data protection policy and the subject access request procedure. This is available on request.
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: if Progressive Financial Services refuses your request under rights of access, we will provide you with a reason as to why.
Where any processing is based on consent, you have the right to withdraw consent at any time. You have the right to request personal data held by the contract provider, by directly asking the contract provider.
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Progressive Financial Services 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, the Data Protection Commissioner and our internal governance.
If you wish to make a complaint about how your personal data is being processed by Progressive Financial Services please let a member of staff know, giving them the opportunity to correct things as quickly as possible.
You may also contact the Data Protection Commission in Ireland to lodge a complaint:
Failure to provide further information
If we are collecting your data for a contract and you cannot provide data as requested the consequences of this could mean the contract cannot be arranged.
Profiling – automatic decision making
Progressive Financial Services uses profiling in two difference instances:
- a) Risk Profilling
- b)Establishing affordability for providing quotations
To establish a customer’s attitude to investment risk, advisors use software which calculate the customers attitude to various levels of risk after the client answers a series of questions.
Establishing affordability & priorities
To establish affordability & priorities Progressive Financial Services conducts a fact find. This relies on the client providing fulsome information on their financial situation and dependents.
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) 901 5582 or by email on email@example.com.
What are cookies?
A cookie is a small piece of data sent from a website and stored in your web browser while you are browsing a website. We use the following type of cookies;
These cookies are anonymous – which means that they won’t collect information to identify you. We use performance cookies to help us improve our website and our online services. These cookies gather information about how our site is used, including which pages you visit most often.
How to manage your cookies:
You can delete cookies stored on your computer or change your privacy settings at any time via your browser settings.
Progressive Financial Services will assume that you agree to the placement of cookies on your device unless you specifically choose not to receive our cookies. Progressive Financial Services uses Google Analytics to collect information about how you use our website.