PRIVACY POLICY

Stephen Murphy Financial Services Privacy Policy.

Last Updated: October 2024

GDPR PRIVACY NOTICE October ‘24

Introduction

Stephen Murphy Financial Services 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 Stephen Murphy Financial Services in relation to the information we collect about you.

For the purposes of the GDPR the data controller is:

Stephen Murphy
Contact details of Stephen Murphy Financial Service (as above)
When we refer to ‘we’ it is Stephen Murphy Financial Services

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?

Stephen Murphy Financial Services is a financial services brokerage firm. We provide customers and potential customers financial advice in relation personal protection e.g. life insurance, specified illness insurance. income protection insurance. Advice on Pensions and PRSA's Post retirement solutions ARF’s annuities and Investment advice

Data protection representatives can be contacted directly here:

Stephen Murphy

stephenmurphyfinancialservices@gmail.com
087 8546879

Purpose for processing your data

The data we require from our customers and potential customer would be contact information e.g.
telephone and email details this is stored on an encrypted computer and or stored on hard copy files which are
locked in the office of Stephen Murphy Financial Services. Other information required medical information for
underwriting purposes for protection business and IBAN and BIC for direct debts Proof of PPSN for pension business etc. and photo id and proof of address for AML requirements this information is also passed onto the relevant life companies who are the product providers
Life companies of October'24 are Zurich Life, Irish Life, Aviva Life, Royal London, New Ireland Assurance, Greenman Investments and BCP Assets Management .

How do we collect your information and what information do we collect?

The personal information we collect varies depending upon the nature of our services. Your information will only be held on Stephen Murphy Financial Services computers and smart phone and on all life companies as listed above

We will endeavour to provide you with an overview of those categories of personal data our organisation collects and our purpose for using that data.

Our organisation collects personal data in the following ways, if you:

request a service from us you wish to apply for a protection policy PRSA, personal pension, Investment, ARF, Company pension kept on our encrypted computers on paper files locked in our office or on a smart phone examples of information required proof of PPSN, proof of address, recent bank statements, photo identification medical information for protection applications proof of income for financial review to make recommendation and company registration number etc for setting up company pensions
use our website/apps and it installs cookies or other tracking technologies onto your device.

How do you store, use, share, and disclose your site visitors' personal information?

Our website is hosted on the Wix.com platform, which provides us with the tools to offer and sell our products and services to you. As part of this service, Wix may collect, store, and process personal information on our behalf. Below are key details regarding how your information is handled:

Data Storage: Your personal data is securely stored on Wix’s servers, which are protected by advanced security measures such as firewalls.
Data Usage: We use your personal information to provide services, process transactions, and communicate with you. Any data collected through our website is used in accordance with this privacy policy and relevant legal obligations.
Data Sharing and Disclosure: Wix may collect and share certain data to provide and improve their services, but these practices are governed by Wix’s privacy policy. For more details on how Wix uses and shares data, you can review their policy here: Wix Privacy Policy.
Cookies and Tracking Technologies: Wix uses cookies and similar technologies to track

website activity and improve user experience. The use of these technologies is also covered by Wix’s privacy policy.

Cookies and Tracking Technologies

We may use cookies, web beacons, and other tracking technologies to collect information about your browsing behaviour on our website. This information is used to improve our services, analyse trends, and personalise your experience.

Security of Your Data

We implement appropriate technical and organizational measures to protect your data from unauthorized access, loss, or misuse. These include encryption, secure servers, and restricted access to personal data. As our website is hosted on Wix, we also rely on Wix’s security
measures, which include SSL encryption and firewalls.

What information do we collect?

The information we collect about you includes the following:

1. Contact and Identifying information, e.g., name, address, contact details; email, mobile, landline

2. Unique identifiers e.g.

PPS number – the reason why we collect your PPS number This is outlined above
pension scheme reference number- the reason why we collect. This is outlined above
insurance policy numbers, the reason why we collect this is so were can review our customers policies in detail

3. Demographic details, age, gender, marital status, lifestyle, and insurance requirements; date of birth, dependents, photo ID, as well as collecting personal information about you, we may also use personal information about other people, for example family members
you wish to insure on a policy. E.g., your children/spouse

4. Family and Beneficiary Data, e.g., dependants, next of kin or nominated beneficiaries,
Power of Attorney, Enduring Power of Attorney. Details of Solicitor/Tax Advisor/Accountant.
5. Employment information e.g., role, employment status (such as full/part time, contract), salary information, employment benefits, and employment history; This information is necessary for our Financial Review with our clients.
6. Publicly available sources: e.g., Information about you in the public domain such as Director information from the Companies Registration Office.
7. Health information such as information about your health status, medical records and medical assessment outcomes; We collect medical information relating to personal habits (e.g., smoking and consumption of alcohol), medical history. We may also process certain
special categories of information, for example information about your personal characteristics (biometric information) or disability information.
8. Pensions and Insurance Benefits information such as current benefits, pension entitlement information, date of retirement and any relevant matters impacting your benefits such as voluntary contributions, PAO.
9. Financial details e.g., bank account details, details of your credit history and bankruptcy
status, salary, tax code, third-party deductions, bonus payments, benefits and entitlement data, national insurance contributions details.
10. Claims Data (From you and any relevant third parties).

11. Marketing preferences: we will only send you direct marketing if you explicitly consent

Online information: e.g., information about your visits to our websites use our website/apps and it installs cookies or other tracking technologies onto your device.

How do you store, use, share, and disclose your site visitors' personal information?
Our website is hosted on the Wix.com platform, which provides us with the tools to offer and sell our products and services to you. As part of this service, Wix may collect, store, and process personal information on our behalf. Below are key details regarding how your information is handled:

Data Storage: Your personal data is securely stored on Wix’s servers, which are protected by advanced security measures such as firewalls.
Data Usage: We use your personal information to provide services, process transactions, and communicate with you. Any data collected through our website is used in accordance with this privacy policy and relevant legal obligations.
Data Sharing and Disclosure: Wix may collect and share certain data to provide and improve their services, but these practices are governed by Wix’s privacy policy. For more details on how Wix uses and shares data, you can review their

policy here: Wix Privacy Policy.

Cookies and Tracking Technologies: Wix uses cookies and similar technologies to track website activity and improve user experience. The use of these technologies is also covered by Wix’s privacy policy.

Cookies and Tracking Technologies
We may use cookies, web beacons, and other tracking technologies to collect information about your browsing behaviour on our website. This information is used to improve our services, analyse trends, and personalize your experience.

Security of Your Data
We implement appropriate technical and organizational measures to protect your data from unauthorized access, loss, or misuse. These include encryption, secure servers, and restricted access to personal data. As our website is hosted on Wix, we also rely on Wix’s security measures, which include SSL encryption and firewalls.

13. Events information e.g., information about your interest in and attendance at our events, including provision of feedback forms.
14. Social media information (e.g., likes and posts) with our social media presence; this
includes, LinkedIn.

15. Searches that we undertake in relation to sanctions and money laundering collecting of photo id, proof of address PPSN and reporting any suspicious behaviour to An Garda Siochana and adhere to Broker’s Ireland Guidence in relation to Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, Criminal Justice (Money Laundering and Terrorist Financing (Amendment) Act 2018, Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021 and The Central Bank of Ireland’s Anti-Money Laundering and Countering the Financing of Terrorism Guidelines for the Financial Sector 2021

When our organisation collects sensitive personal data as defined within the GDPR we will ensure that we require this information, and we have your explicit consent and/or authorisation prior to our collection. Please see the further information contained in this Privacy Notice that outlines special categories of personal data.

Information we automatically collect.

We sometimes automatically collect certain types of information when you visit our websites and through e-mails when we communicate with you. Automated technologies may include the use of web server logs to collect IP addresses, "cookies" and web beacons. Other cookies such as functional cookies, marketing cookies and analytical cookies will only be used with your expressed consent. Further information about our use of cookies can be found in our Cookie Notice at the footer of our web page.

How do we use your personal data?
Your Personal Data will be used to enable us to fulfil our contractual obligations in relation to your
request for insurance, investment, protection, pension products, independent financial advice, quotes.

1. Performing services for our clients and prospective clients – when you require insurance/investment products, we use your data to enable us to provide the required product

2. Statutory and other regulatory requirements – we are required to carry out various obligations which include:

AML/Sanction checking Searches that we undertake in relation to sanctions and money laundering collecting of photo id, proof of address PPSN and reporting any suspicious behaviour to An Garda Siochana and adhere to Broker’s Ireland Guidence in relation to Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, Criminal Justice (Money Laundering and Terrorist Financing (Amendment) Act 2018, Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021 and The Central Bank of Ireland’s Anti-Money Laundering and Countering the Financing of Terrorism Guidelines for the Financial Sector 2021
Knowing your customer “Fact Find”
Adherence to the Consumer Protection Code

3. Communicate and marketing to you. Contact directly by phone email, WhatsApp or letter
4. Process claims – claims are forwarded directly to the life company or companies involved by email or by phone
5. To contact you if required or to respond to any communications that you might send to us.
6. Carry out our obligations arising from any contracts entered between you and us and to provide you with the information, products and services that you request.

7. Handling complaints please refer to our Terms of Business
8. To notify you about changes to our service

Legal Basis
We need to ensure that we process your personal data lawfully. We rely on the following legal grounds to
collect and use your personal data.
Performance of a contract

When we enter a contract with you, we will collect and use your personal data to enable us to fulfil that service.

Legal obligation

The use of some of your personal data is necessary for us to meet our legal obligations e.g., pension contributions for Revenue Certificates, Regulatory purposes to the Central Bank.

Consent

Sometimes we may rely on consent as a legal basis for processing your information. For example, we rely on consent to collect and use personal data for any criminal convictions or alleged offences. This is used when we need to assess risk relating to
an insurance policy for you. We share this information with other third parties where it is necessary to manage these services provided to you – these services include insurance underwriters, reinsurer and other insurance providers.

We may also rely on your consent to send direct marketing to you. We will ensure that we present this to you concisely. We will also ensure that we use clear and plain language and if you give us your consent you can withdraw this easily at any time.

Sometimes if you refuse to provide information that we reasonably require to provide the services, we may be unable to offer you the services and/or we may terminate the services provided with immediate effect.

Legitimate interests

Where we rely on this legal basis to collect and use your personal information, we shall take appropriate steps to ensure the processing does not infringe the rights and freedoms conferred to you under the applicable data privacy laws.

Vital interest

Public interest

If you require further information on any of the above basis for processing your data, we can provide you with further details.

How we share your data
When required, we may make your information available to third parties with whom we have a relationship, where that third party is providing services on our behalf. We will only provide those third parties (data processors) with information that is necessary for them to perform the services. We will take measures to protect your information, such as putting in place Standard Contractual Clauses and
confidentiality agreements.
1. Insurance Partners where we need to manage the services provided to you such as Product Providers and insurance underwriters, reinsurers, and loss adjuster. You can refer to their privacy statements on their website for more information about their privacy practices.
Irish Life , Zurich Life, Aviva Life, Royal London, New Ireland Assurance, BCP Assets Management and Greenman Investment (the links to these companies are available on request)
2.Legal advisers, loss adjusters, and claims investigators, where necessary to investigate, exercise or defend legal claims , insurance claims or other claims of a similar nature.
3. Medical professionals, e.g., where you provide health information in connection with a claim against your insurance policy; or when we are providing a quote for insurance.
4. EU Law enforcement bodies, when required to do so by law and/or regulation, or another legal request.
5. Public authorities, regulators and government bodies, where necessary for us to comply with our legal and regulatory obligations, or in connection with an investigation of suspected or actual illegal activity;
7. Internal and external auditors where necessary for the conduct of company audits or to investigate a complaint or security threat.
8. On the sale or reorganisation of our business whether by asset or share disposal or other transaction relating to our business.

Retention
Stephen Murphy Financial Services shall not keep personal data in a form that permits identification of data subjects for a longer period than is necessary.

Stephen Murphy Financial Services may store data for longer periods if the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the implementation of appropriate technical and organisational measures to safeguard the rights and freedoms of the data subject.

The retention period for each category of personal data will be set out in our Retention Schedule along with the criteria used to determine this period, including any statutory obligations we have.

Personal data will be disposed of securely.

Data Subjects Rights: Stephen Murphy Financial Services will facilitate your 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. (The erasure of such data will be dependent on our other legal obligations, and whether the data is subject of legal privilege).
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.
Right to make a complaint: if we refuse your request under rights of access, we will provide you with a reason as to why.

All 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.

Complaints
If you wish to make a complaint about how your personal data is being processed by Stephen Murphy Financial Services or how your complaint has been handled, you have the right to lodge a complaint with our Data Protection Officer Stephen Murphy.

You may also lodge a complaint with the Data Protection Commission (DPC) in Ireland, whose details are:

Data Protection Commission
21 Fitzwilliam Square South,
Dublin 2.
D02RD28
Web: www.dataprotection.ie
Email: info@dataprotection.ie

See website for updated contact details to reach the appropriate section within the DPC.

Failure to provide further information.

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. When you fail to provide us with information we require to fulfil our obligations to you, we may be
unable to offer our services to you.

Special Categories of personal data
Special categories of data are sensitive in relation to your fundamental rights and freedoms and therefore require specific protection when processed as these could create significant risks to the rights and freedoms of individuals.

If we collect any special categories of personal data, such as health data, we will either obtain your explicit consent or we will adhere to the Data Protection Act 2018. This Act allows us to process special categories of personal data for insurance and pension purposes. We will ensure we have suitable and specific measures in place to safeguard the rights and freedoms of you and the processing of your data.

These measures relate to the below:

a policy of insurance or life assurance,
a policy of health insurance or health related insurance
an occupational pension, a retirement annuity contract or any other pension arrangement

Contact Us
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 087 8546879 or email stephenmurphyfinancialservices@gmail.com

Privacy notice/ statement changes
When we update this Privacy Notice/Statement, we will post a revised version online. Changes will be effective from the point at which they are posted. We would encourage you to review our Privacy Notice so that you are aware of updates.

This privacy policy was last reviewed in October ‘24