Privacy Policy

Privacy Notice – Version Effective from 25^th May 2018.

Introduction

The General Data Protection Regulation (“GDPR”) is effective from 25th May 2018 and is the first major revision of data protection rights and responsibilities at European level since 1995. This regulation, along with applicable Irish legislative changes, amends existing data protection law in Ireland and creates enhanced accountability and transparency obligations for all companies who process personal data, as well as granting new and enhanced rights for individuals.

Reklaw Ltd t/as Walker Financial Management (hereafter referred to as Walker Financial Management) 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 Walker Financial Management in relation to the information we collect about you.

For the purposes of the GDPR the data controller is:

• Walker Financial Management

• Contact details of Mr. Jeremy Walker

• When we refer to ‘we’ it is Walker Financial Management

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?

Walker Financial Management advises our valued corporate and personal clients on how to manage their money in a tax efficient, cost-effective and structured manner.

Our business was founded in 2009 by Jeremy Walker who set out with one very simple aim: to help and guide clients to identify their financial aspirations and to gain control of their financial futures. With over 36 years’ experience in the financial services industry (in Ireland and the UK), Jeremy has the necessary depth of knowledge and experience to advise clients on charting the course to their personal financial goals.

WFM advises professionals and business owners on all aspects of their financial health. This includes budgeting, tax planning, risk planning (insurance) and wealth management. We help our clients to ensure they have structures in place to manage the financial wellbeing of themselves, their families and businesses in the event of any unforeseen instances, such as ill health or even death. We then help them to optimise both their current financial wealth and their future financial potential. We have deep experience in all investment related matters including managed investment portfolios, Small Self-Administered Pension Schemes (SAPS), self-administered Personal Retirement Savings Accounts and self-administered Approved Retirement Funds. This experience affords us the opportunity to develop innovative and highly bespoke solutions for each of our clients.

Our GDPR Owner and data protection representatives can be contacted directly here:

• Mr. Jeremy Walker, Ms. Teresa McKeown

• jeremy@wfm.ie, teresa@wfm.ie

• 01-6510613

How we will collect your data?

We collect data about you when you apply for products provided by a third party or our services and during the course of your relationship with us, for example, when you request or complete transactions, or indeed when you request additional services or products.

What data do we collect?

We may collect data under a number of categories, including (but not restricted to):

 

• Identification & Contact Information, including your Name, Date of Birth, Gender, Marital Status, PPS Number, Address, Email Address, Home Phone Number, Work Phone Number, Mobile Number, Fax Number.

• Financial Details & Financial Information, including your Occupation, Job Title, Total Income (earned and unearned), Date your Employment Commenced, % Shareholding (if applicable), Existing Retirement Planning, Employer Name, Bank Details, Tax Residence, Date Employment Ended.

• Special Categories of Personal Data, including Health Data or in certain cases Data Relating to Criminal Convictions. Such data will only be processed where this is a requirement in order to provide our services to you or where it is required under a legal obligation to which Walker Financial Management is subject.

• Other Personal Information, including information provided by you during the course of your relationship with us such as data to complete a transaction or enter an investment on your behalf.

Purpose for processing your data

Walker Financial Management will only ever use your information for a limited number of purposes, including:

• To provide advice in relation to products and services in line with the contract between us, including protection, pensions, investment and other financial products and other services including, but not limited to, taxation advice.

• We may require your data to confirm your eligibility for certain products and to process transactions at your request.

• To comply with our legal and regulatory obligations, including establishing your identity, residence and tax status in order to comply with laws and regulations in the areas of taxation, financial crime, anti-money laundering and counter-terrorist financing, or to comply with court orders, enactments or rules of law or the instructions of regulatory bodies.

• To operate our business in line with our legitimate interests, including managing and improving customer service, risk and compliance monitoring, identifying improvements which can be made to our products and services, maintaining and improving our security systems and for conducting marketing activities.

• To protect your vital interests or those of another natural person.

• Where you have given your consent for direct marketing.

Why we are processing your data? Our legal basis.

In order for us to provide you with our service, Walker Financial Management need to collect personal data for the purposes of providing advice on products and services as detailed above. Our reason (lawful reason) for processing your data under the GDPR is:

• Legal basis – Walker Financial Management 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, Walker Financial Management 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 Walker Financial Management use the personal data it collects about me?

Walker Financial Management 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.

Special Categories of personal data

If we collect any special categories of personal data (e.g. health, 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

• such data will only be processed where this is a requirement in order to provide our services to you or where it is required under a legal obligation to which Walker Financial Management is subject
   

Who are we sharing your data with?

We will keep your personal data confidential but may disclose it to third parties where necessary for the purpose of providing the products or services that you have requested, including associated companies, financial institutions, your authorised representatives including your accountant (where we have obtained specific permission beforehand to do so) and other parties with whom we have contractual arrangements to provide ancillary and support services.

We may also share your data with regulatory and other governmental bodies where required by or under any enactment or rule of law or court order, including, but not limited to, the Revenue Commissioners, An Garda Siochana, the Companies Registration Office, the Incorporated Law Society, the Irish Taxation Institute, the Pensions Authority, the Financial Services & Pensions Ombudsman or the Central Bank of Ireland. If we are required to make such a disclosure, we may not be able to tell you that a disclosure has been made and we may have to stop providing our services to you for a period of time and may not be able to tell you why.

We have issued all our third party processors with a Data Processor checklist asking them GDPR specific questions.

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:

Walker Financial Management facilitates our client’s 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 Walker Financial Management 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. Walker Financial Management 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.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Walker Financial Management or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Walker Financial Management GDPR Owner.

Failure to provide further information

If we are collecting your data for a contract and you cannot provide certain data the consequences of this could mean the contract cannot be completed or details are incorrect.

Profiling – automatic decision making

In order to establish a customer’s attitude to investment risk (in relation to pensions and investments) the software engaged by Walker Financial Management calculates our client’s attitude to various levels of risk having answered a series of questions.

Additional Processing

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.

Contact Us

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 01- 6510613 or email jeremy@wfm.ie, teresa@wfm.ie

Privacy policy statement changes

Walker Financial Management may change this privacy policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically so you’re aware of any changes. By using our services you agree to this privacy policy.

This privacy policy was last reviewed in May 2018