Data protection privacy statement – Keaney Insurance Brokers Ltd
Keaney Insurance Brokers Ltd 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, and compliant, 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 Keaney Insurance Brokers Ltd in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
- Keaney Insurance Brokers Ltd
- Contact details:
Compliance Department, Keaney Insurance Brokers Ltd, 30 Lower Leeson Street, Dublin 2.
- When we refer to ‘we’ it is Keaney Insurance Brokers Ltd
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?
Keaney Insurance Brokers Ltd. provide insurance broking, claims management, consulting, and other forms of insurance services
Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:
Keaney Insurance Brokers Ltd
30 Lr. Leeson Street
|Contact Name||Terry Keaney|
|Contact no:||01 661 8080|
Purpose for processing your data / types of data
The Personal Information we may collect about you will depend on the type of Service we are providing and the relationship between us but may include:
- Name and contact information;
- Demographic information (such as gender, age, date of birth, marital status, nationality, education/work histories, academic/professional qualifications, employment details, hobbies, family composition, and dependents);
- Personal identification documentation and related information such as passport numbers and employee identification numbers, including PPS number;
- Financial and payment date such as bank account numbers and transaction information;
- Information related to the provision of the Services, such as policy information, claims information, and information relating to incidents giving rise to claims and related losses;
- Information about your property and assets;
- Documentation obtained to satisfy anti money laundering requirements;
- Statements made by or about you;
- Records of communications and CCTV footage; and
- Human resources data, such as job title and role; benefits and compensation information; educational, academic and professional qualifications information; emergency contact information; and performance management information.
Some of the categories of information that we collect are special categories of Personal Information (“Sensitive Personal Information”). These include your medical information and criminal records, fines and other like judicial records.
How we may use your personal information
We use your personal information:
- to provide the services and fulfil our contractual obligations to you and for legitimate business interests.
- to operate and expand our business activities
- to perform administrative activities in connection with our services
- to exercise, defend or protect our legal rights or the rights of our clients or third parties
- to comply with legal and professional obligations and to cooperate with regulatory bodies
- claims handling
- sharing details or seeking personal information from Insurers (if applicable) and anyone authorized by you to act on your behalf
- sharing details with or seeking personal information from loss adjusters, repairers and other claims handling agents, medical practitioners, engineers and legal practitioners
- to process any payments whether in relation to your policy or a claim
- to manage and investigate any complaints
- to make back-ups of your data in case of an emergency and for disaster recovery purposes
We may record or monitor calls for regulatory, training and quality purposes
If you hold insurance against a liability that may be incurred by you against a third party, where for whatever reason you cannot be found or you become insolvent, or the court finds it just and equitable to so order, then your rights under the contract will be transferred to and vest in the third party even though they are not a party to the contract of insurance, The third party has a right to recover from the insurer the amount of any loss suffered by them. Where the third party reasonably believes that you as policyholder have incurred a liability the third party will be entitled to seek and obtain information from the insurer or from any other person who is able to provide it concerning:
- The existence of the insurance contract,
- Who the insurer is,
- The terms of the contract, and
- Whether the insurer has informed the insured persons that the insurer intends to refuse liability under the contract.
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
In most cases the legal basis will be one of following:
We must have a legal basis to process your Personal Information. In most cases the legal basis will be one of the following:
- to provide services to you under a contractual obligation
- For our legitimate interests, for example to provide Services to you, to ensure that the Services we provide are appropriate for your requirements, to improve our Services, manage our risks, maintain accurate transaction records, and manage our business in an efficient way;
- For the legitimate interest of our clients and other third parties (for example to investigate and assess claims made against policies held or underwritten by them and to prevent and detect suspicions of fraud); or
- To comply with our legal obligations such as due diligence and reporting obligations
We process Sensitive Personal Information on the following legal basis:
- With your consent, where consent is required by law. You may withdraw your consent at any time by contacting us using the details at the end of this privacy notice;
- To establish, exercise or defend legal claims; or
- Where legislation otherwise permits and requires us to process Sensitive Personal Information (for example, where the processing is necessary for insurance purposes).
Keaney Insurance Brokers 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.
Who are we sharing your data with?
We may share your personal data with third parties
Any Keaney Insurance Brokers Ltd associated company for the use and purposes as set out above
- External parties in order to administer your policy
Example other insurance companies and intermediaries
- Anyone authorized to act on your behalf
- Third party service providers such as technology suppliers, hosting/storage providers, payment providers and document providers
- As a result of our legal and regulatory obligations, this can include with an Garda Siochana, other official agencies, and on foot of a court order or subpoena.
- Loss adjusters, claims investigators, repairers, medical practitioners, solicitors, and other firms as part of the claims handling process
- with perspective sellers or buyers in the event that we decide to sell or buy any business or assets.
Where we obtain data from these sources, the categories we obtain will be personal data or claims information, relating to the services provided.
We may also need your consent for the processing of certain data and in these cases, we will inform you of such processing the reason for this at the time consent is captured.
Some of your personal information may be sent to other parties outside of the EU.
If we do 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.
If we are to engage with parties outside of the EU, where possible we will notify you in advance of such engagement. We will further use our best endeavours to ensure that your personal information is dealt with securely and that prior and proper permission has been obtained to share personal information with us.
We may pass your personal data on to third-party service providers contracted to Keaney Insurance Brokers 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 fulfil the service they provide on your behalf. When they no longer need your data to fulfill this service, they will dispose of the details in line with Keaney Insurance Brokers Ltd procedures.
Data Subjects Rights:
Keaney Insurance Brokers Ltd 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 appropriate external review: in the event that Keaney Insurance Brokers Ltd 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.
If you provide us with information about someone else, we will endeavour to provide this Privacy Statement to them, for example an additional driver, an additional insured. Where this is not possible, you must make them aware of the notice and the terms of the insurance.
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Keaney Insurance Brokers Ltd 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.
In the event that you wish to make a complaint about how your personal data is being processed by Keaney Insurance Brokers Ltd or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Keaney Insurance Brokers Ltd. data protection representatives email@example.com
You may also contact the Data Protection Commission in Ireland to lodge a complaint (details below).
Data Protection Commission
Co. Laois, R32 AP23
Phone: + 353 57 868 4800 / + 353 761 104 800
Fax: + 353 57 868 4757
Failure to provide further information
If we are collecting your data for a contract x and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.
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.