Policy Prepared For: Linked Pensions & Investments Ltd
Linked Pensions & Investments Ltd needs to gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards thus complying with the legislation.
While using Our Service, We may ask You to provide Linked Pensions & Investments Ltd with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
When You pay for a product and/or a service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:
This data protection policy ensures Linked Pensions & Investments Ltd:
The General Data Protection Regulation (GDPR) describes how organisations — including Linked Pensions & Investments Ltd, must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
Data subjects have the following rights regarding data processing, and the data that is recorded about them:
All individuals who are the subject of personal data held by Linked Pensions & Investments Ltd are entitled to:
Should an Individual contact the company requesting this information, this is called a Subject Access Request.
Subject Access Requests from individuals should be made by email, addressed to the data controller at (email address). The data controller can supply a standard request form, although individuals do not have to use this.
The data controller will aim to provide the relevant data within 30 days.
The data controller will always verify the identity of anyone making a subject access request before handing over any information.
Linked Pensions & Investments Ltd understands ‘consent’ to mean that it has been explicitly and freely given, and a specific, informed and unambiguous indication of the data subject’s wishes that, by statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. The data subject can withdraw their consent at any time.
Linked Pensions & Investments Ltd understands ‘consent’ to mean that the data subject has been fully informed of the intended processing and has signified their agreement, while in a fit state of mind to do so and without pressure being exerted upon them. Consent obtained under duress or on the grounds of misleading information will not be a valid basis for processing.
There must be some active communication between the parties to demonstrate “active consent”. Consent cannot be inferred from non-responsive communications. The controller must be able to demonstrate that consent was obtained for the processing operation.
For sensitive data, explicit consent from data subjects must be obtained unless an alternative legitimate basis for processing exists.
All Employees/Staff are responsible for ensuring that any personal data that Linked Pensions & Investments Ltd holds and for which they are responsible, is kept securely and is not, under any conditions, disclosed to any third party unless that third party has been specifically authorised by Linked Pensions & Investments Ltd to receive that information and has entered into a confidentiality agreement.
All personal data should be accessible only to those who need to use it, and access may only be granted in line with the Access Control Policy.
All personal data should be treated with the highest security and must be kept:
Care must be taken to ensure that PC screens and terminals are not visible except to authorised Employees/Staff of Linked Pensions & Investments Ltd. All Employees/Staff are required to enter into an Acceptable Usage Agreement before they are given access to organisational information of any sort, which details rules on screen time-outs etc.
Manual records may not be left where they can be accessed by unauthorised personnel and may not be removed from business premises without explicit (written) authorisation. As soon as manual records are no longer required for day-to-day client support, they must be removed from secure archiving in line with your policies.
Personal data may only be deleted or disposed of in-line with the Retention of Records Procedure Manual.
Records that have reached their retention date are to be shredded and disposed of as ‘confidential waste’. Hard drives of redundant PCs are to be removed and immediately destroyed, as required before disposal.
Processing of personal data ‘off-site’ presents a potentially greater risk of loss, theft or damage to personal data. Staff must be specifically authorised to process data off-site.
Linked Pensions & Investments Ltd must ensure that personal data is not disclosed to unauthorised third parties which includes family members, friends, government bodies, and in certain circumstances, the Gardaí/Police. All Employees/Staff should exercise caution when asked to disclose personal data held on another individual to a third party. It is important to consider whether disclosure of the information is relevant to, and necessary for, the conduct of Linked Pensions & Investments Ltd business.
All requests to provide data for one of these reasons must be supported by appropriate paperwork and all such disclosures, must be, specifically authorised by the GDPR owner.
Linked Pensions & Investments Ltd shall not keep personal data in a form that permits identification of data subjects for a longer period than is necessary, in relation to the purpose(s) for which the data was originally collected.
Linked Pensions & Investments Ltd 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 the Retention of Records Procedure, along with the criteria used to determine this period, including any statutory obligations Linked Pensions & Investments Ltd has, to retain the data.
Linked Pensions & Investments Ltd Data Retention, Data Disposal and Storage Removal Procedures will apply in all cases.
Personal data must be disposed of securely, in accordance with the sixth principle of the GDPR. Thus, processed in, an appropriate manner, to maintain security, thereby, protecting the “rights and freedoms” of data subjects. Any disposal of data, will be done in accordance with the Secure Disposal Procedure.
All exports of data from within the Non-European Economic Area (EEA) countries (referred to in the GDPR as ‘third countries’) are unlawful unless there is an appropriate “level of protection for the fundamental rights of the data subjects”.
The transfer of personal data outside of the EEA is prohibited unless one or more of the following specified safeguards, or exceptions, apply:
The European Commission can and does assess third countries, a territory and/or specific sectors within third countries to assess whether there is an appropriate level of protection for the rights and freedoms of natural persons. In these instances, no authorisation is required.
Countries that are members of the European Economic Area (EEA) but not of the EU are accepted as having met the conditions for an adequacy decision.
A list of countries that currently satisfy the adequacy requirements of the Commission are published in the Official Journal of the European Union. (Please see “Related Documentation” section below).
Linked Pensions & Investments Ltd may adopt, approved binding corporate rules for the transfer of data outside the EU. This requires submission to the relevant supervisory authority for approval of the rules that Linked Pensions & Investments Ltd is seeking to rely upon.
Linked Pensions & Investments Ltd may adopt approved model contract clauses for the transfer of data outside of the EEA. If Linked Pensions & Investments Ltd adopts the (model contract clauses approved by the relevant supervisory authority), there is an automatic recognition of adequacy.
In the absence of an Adequacy Decision, Privacy Shield membership, Binding Corporate Rules and/or Model Contract Clauses, a transfer of personal data to a third country or international organisation shall only take place on one of the following conditions:
Linked Pensions & Investments Ltd has established a data inventory and data flow process as part of its approach to address risks and opportunities throughout its GDPR compliance project namely;
Linked Pensions & Investments Ltd is aware of all risks associated with the processing of, specific types of personal data.
Linked Pensions & Investments Ltd assesses the level of risk to individuals associated with the processing of their personal data. Data Protection Impact Assessments (DPIAs) are carried out in relation to the processing of personal data by Linked Pensions & Investments Ltd and in relation to processing undertaken by other organisations on behalf of Linked Pensions & Investments Ltd.
Linked Pensions & Investments Ltd shall manage any risks identified by the risk assessment, to reduce the likelihood of a non-conformance with this policy.
Where a type of processing, particularly using new technologies and considering the nature, scope, context and purposes of the processing is likely to result in a high risk to the rights and freedoms of natural persons, Linked Pensions & Investments Ltd shall, prior to the processing, carry out a Data Protection Impact Assessment (DPIA) of the impact of the envisaged processing operations on the protection of personal data. A single Data Protection Impact Assessment (DPIA) may address a set of similar processing operations that present similar high risks.
Following the result of a Data Protection Impact Assessment (DPIA), it is clear that Linked Pensions & Investments Ltd is about to commence processing of personal data that could cause damage and/or distress to the data subjects, the decision as to whether Linked Pensions & Investments Ltd may proceed must be escalated for review to the GDPR Owner.
The GDPR Owner shall, if there are significant concerns, either as to the potential damage or distress, or the quantity of data concerned, escalate the matter to the supervisory authority.
This policy helps to protect Linked Pensions & Investments Ltd from potentially, serious data security risks, including:
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the GDPR Owner.
When data is stored in paper format, it should be kept in a secure place where unauthorised people cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
Linked Pensions & Investments Ltd website protects data online by having a secure cloud server that’s protected by a secure Firewall system from preventing hacks and a has a secure SSL (Secure Socket Layer) which encrypts all the communication between Our online website www.digitaldestiny7.sg-host.com and You.
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Personal data is of no value to Linked Pensions & Investments Ltd unless the business can make use of it. However, it is when personal data is accessed and used, that it can be at the greatest risk of loss, corruption or theft. For example:
Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies here: www.allaboutcookies.org.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary cookies are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.
Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.
Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.
Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.
Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet.
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
We may use third-party Service providers to monitor and analyze the use of our Service.
We may use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymised statistical data about Our users.
For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.
Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Linked Pensions & Investments Ltd by following the unsubscribe link or instructions provided in any email We send or by contacting Linked Pensions & Investments Ltd.
We may use Email Marketing Service Providers to manage and send emails to You.
These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies and to enable Linked Pensions & Investments Ltd to:
Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:
You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.
The third-party vendors We use are:
Usage, Performance and Miscellaneous
We may use third-party Service Providers to provide better improvement of our Service.
The law requires Linked Pensions & Investments Ltd to take reasonable steps to ensure data is kept accurately and up to date.
The higher the importance, that the personal data is accurate, the greater the effort Linked Pensions & Investments Ltd should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps, to ensure it is kept as accurate and up to date as possible.
In certain circumstances, GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Linked Pensions & Investments Ltd will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board of directors and from the company’s legal advisers, where necessary.
Linked Pensions & Investments Ltd aims to ensure that individuals are aware that their data is being processed, and that they understand:
To this end, the company has a Privacy Statement, setting out how data relating to individuals is used by the company.
Linked Pensions & Investments Ltd is a Data Controller under the GDPR.
Top Management and all those in managerial or supervisory roles throughout Linked Pensions & Investments Ltd are responsible for developing and encouraging good information handling practices within Linked Pensions & Investments Ltd; responsibilities are set out in individual job descriptions.
The GDPR Owner have specific responsibilities in respect of procedures such as the Subject Access Request Procedure and are the first point of call for Employees/Staff, seeking clarification on any aspect of data protection compliance.
Compliance with data protection legislation is the responsibility of all Employees/Staff of Linked Pensions & Investments Ltd who process personal data.
Linked Pensions & Investments Ltd Training Policy sets out specific training and awareness requirements in relation to specific roles and Employees/Staff of Linked Pensions & Investments Ltd generally.
Employees/Staff of Linked Pensions & Investments Ltd are responsible for ensuring that any personal data about them and supplied by them to Linked Pensions & Investments Ltd is accurate and up-to-date.
Everyone who works for or with Linked Pensions & Investments Ltd has some responsibility for ensuring data is collected, stored and handled appropriately.
However, these people have key areas of responsibility:
Material scope (Article 2.)
The GDPR applies to the processing of personal data wholly or partly by automated means (i.e. by computer) and to the processing other than by automated means of personal data (i.e. paper records) that form part of a filing system or are intended to form part of a filing system.
Territorial scope (Article 3.)
The GDPR will apply to all controllers that are established in the EU (European Union) who process the personal data of data subjects, in the context of that establishment. It will also apply to controllers outside of the EU that process personal data in order to offer goods and services, or monitor the behaviour of data subjects who are resident in the EU.
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions used by the company drawn from the General Data Protection Regulation (GDPR)
Unique account created for You to access our Service or parts of our Service.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Linked Pensions & Investments Ltd, 6 Pearse Court, Pearse Street, Athlone, Co Westmeath..
For the purpose of the GDPR, the Company is the Data Controller.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Facebook Fan Page
Facebook Fan Page is a public profile named Linked Financial specifically created by the Company on the Facebook social network, accessible from https://facebook.com/linkedfinancial
Service refers to the Website.
Third-Party Social Media Service
Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Linked Pensions & Investments Ltd, accessible from https://linkedfinancial.ie/
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
The main establishment of the controller in the EU will be the place in which the controller makes the main decisions as to the purpose and means of its data processing activities. The main establishment of a processor in the EU will be its administrative centre. If a controller is based outside the EU, it will have to appoint a representative in the jurisdiction in which the controller operates to act on behalf of the controller and deal with supervisory authorities.
Any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Special Categories of Personal Data
Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data, for the purpose of, uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law.
Any living individual who is the subject of personal data held by an organisation.
Any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means or not, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Is any form of automated processing of personal data intended to evaluate certain personal aspects relating to a natural person, or to analyse or predict that person’s performance at work, economic situation, location, health, personal preferences, reliability, or behaviour. This definition is linked to the right of the data subject to object to profiling and a right to be informed about the existence of profiling, of measures based on profiling and the envisaged effects of profiling on the individual.
Personal Data Breach
A breach of security leading to the accidental, or unlawful, destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed. There is an obligation on the controller to report personal data breaches to the supervisory authority and where the breach is likely to adversely affect the personal data or privacy of the data subject.
Data Subject Consent
Any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data.
The GDPR and Children
A child is defined currently, as being under the age of sixteen, but member states may consider lowering the legal age of consent to thirteen. The processing of personal data of a child is only lawful if parental or custodian consent has been obtained. The controller shall make reasonable efforts to verify in such cases that consent is given or authorised by the holder of parental responsibility over the child.
A natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Third Party Social Media Service
Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
Any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis.
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 0906 417024 or email us at email@example.com or write to us at Linked Pensions & Investments Ltd, 6 Pearse Court, Pearse Street, Athlone, Co Westmeath.