Earley Consulting 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 that you understand your rights as a client.
It is the intention of this privacy statement to explain to you the information practices of Earley Consulting in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
Earley Consulting Ltd, Distillery Lane, Mill Street, Co. Kildare
Please read this statement carefully as it 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 we are
Earley Consulting is an independently owned Financial Planning Practice established in 2006.
Clients of Earley Consulting benefit from unbiased, impartial financial advice, giving them control, confidence and peace of mind.
We cater for a broad range of clients, from those who want a full financial planning or wealth management service to others who are simply looking for investment advice on how to achieve a better return on the money they have sitting in a bank account.
Our Data Protection Officer can be contacted directly here:
Earley Consulting Ltd
Purpose of processing your data
For us to provide you with a personalised Financial Plan we need to collect personal and financial data which is held by you and/or third parties. We at Earley Consulting 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 Earley Consulting use the personal data it collects about me?
Earley Consulting 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 endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
Earley Consulting is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business sector requirements and agreed practices. Personal data may be held in addition to these periods depending on the individual business needs.
Who are we sharing your data with?
We collect your personal data in order to provide you with the most appropriate advice and/or products applicable to your specific requirements. We may share information with third parties to facilitate this and 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 fulfil this service they will dispose of the details in line with procedures.
A list of the third parties (product providers) is available on request or alternatively is contained in our Terms of Business.
If we transfer personal data 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:
Earley Consulting facilitates your rights (data subject’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
- 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 Earley Consulting refuses your request under rights of access, we will provide you with a reason as to why.
Retention of your personal data
Data will not be hold for longer than is necessary for the purpose(s) for which they were obtained. Earley Consulting will process personal data in accordance with our retention policy. This retention policy has been governed by our regulatory body (Central Bank) and our internal governance and is available on request.
Withdrawal of consent
If we are relying on your consent to process your data, you may withdraw this consent at any time – this does not affect the lawfulness of processing based on your consent before it was withdrawn.
Should you wish to make a complaint about how your personal data is being processed by Earley Consulting, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Earley Consulting’s data protection representatives Data Protection Officer/GDPR Owner.
Failure to provide further information
If we are collecting your data to fulfil a contract (life policy, pension policy, investment/savings plan) and you cannot provide this data, the consequences of this could mean the contract cannot be completed or details are incorrect.
Profiling – automatic decision making
Our risk profile questionnaire aims to establish your attitude to investing, your understanding of financial markets and how you react during certain market & economic conditions. The questionnaire scores 17 questions, which when totalled, along with your capacity and need suggests a particular risk tolerance and investment objective. We use this questionnaire in conjunction with other elements to determine your overall risk tolerance. You have the right to refuse this and decide on your own risk profile.