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This Data Protection Notice explains the most important aspects of how we use personal information and what rights individuals have.
You can get more information about the terms we use and view our Privacy Policy at www.aviva.ie/about-and-support/privacy/ or request a copy by writing to the Data Protection Officer, Aviva Life & Pensions Ireland DAC, Building 12, Cherrywood Business Park, Loughlinstown, Co Dublin. D18 W25P or call us on (01) 8987000.
This Data Protection Notice applies (1) in the case of a proposed new agency, to the intermediary applying to Aviva for an agency appointment; and (2) in the case of an existing agency the intermediary appointed as the non-exclusive intermediary of Aviva (referred to in this notice as “the Intermediary” “You” “Your”).
The terms Intermediary/You/Your includes sub-agents of the Intermediary and director(s), officer(s), partners/principals of the Intermediary and its sub-agents.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we” “us” “our”) as the insurance undertaking the Intermediary holds an appointment with or is applying for an appointment with.
We collect personal information from the Intermediary and any relevant third parties (including that authorised to be collected when setting up an agency account with us) under and in relation to an agency application/agency appointment and the administration of insurance policies set up with us by the Intermediary. Types of personal information may include identity and contact information, qualifications and relevant experience, details of financial circumstances, organisation details, regulatory status, tax details, financial advisor information.
We may ask for/process details relating to any unspent criminal convictions relevant to your appointment. We recognise that information about criminal convictions is particularly sensitive information and we will only collect and use such data as follows:
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. our Terms and Conditions of Appointment as an Insurance Intermediary. For the performance of a contract i.e. our Terms and Conditions of Appointment as an Insurance Intermediary of Aviva (the ``Agency T&Cs``) | To consider whether to accept a request to set-up an agency account with us (including associated due diligence and vetting processes), to consider suitable Commission Arrangements. To administer the agency account of the Intermediary in accordance with the Agency T&Cs, including performing obligations and enforcing rights under the Agency T&Cs. |
We may also need to use criminal conviction data of the Intermediary for the purposes of establishing, exercising or defending legal rights and where authorised by law.
You don’t have to provide us with any personal information, but if you don’t provide the information we need we may not be able to proceed with your application or continue an existing agency appointment.
We may also use personal information about other people, including employees, financial advisers, consultants, agents and sub-contractors of the Intermediary.
If you are providing personal information about another person we require you to let them know what information you’ve shared with us, share with them this Data Protection Notice and obtain their confirmation that they have read and understand this Data Protection Notice. If you or they have any queries or concerns please contact us in one of the ways described below.
We may also collect personal information:
The legal basis we rely on to process personal information and the purposes for which we collect and use personal information are summarised below.
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. our Terms and Conditions of Appointment as an Insurance Intermediary | To consider whether to accept a request to set-up an agency account with us (including associated due diligence, vetting and verification processes) and to consider suitable Commission Arrangements. |
| For the performance of a contract i.e. our Terms and Conditions of Appointment as an Insurance Intermediary of Aviva (the ``Agency T&Cs``) | To administer the agency account of the Intermediary in accordance with the Agency T&Cs, including administering insurance policies set up with us on behalf of your Clients, performing obligations and enforcing rights under the Agency T&Cs (or any Separate Agreement), assessing further agreements or relationships with the Intermediary and the prevention and detection of fraud in relation to the Business conducted under the Agency T&Cs. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations |
| Legitimate Interests (of Aviva and/or the Intermediary) | We may process personal information of people other than the Intermediary to administer the agency account for the benefit of you and your Clients, including administering insurance policies set up with us by the Intermediary. |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as a business in managing our legal affairs including exercising our legal rights and defending claims (including debt management and recovery); and managing our business effectively e.g. with third party service suppliers. |
| Legitimate Interests (of Aviva) | To support other legitimate interests that we have as a business and that the insurance industry at large has to manage security including preventing, detecting, investigating and/or protecting our customers and ourselves from financial crime, theft and fraud. |
| Legitimate Interests (of Aviva) | Our legitimate interests to improve service enhancement and business performance, this includes relationship management; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services (including WriteNow & Aviva BrokerSecure); and in the event of any portfolio transfer, merger, acquisition, disposal or other such transaction relating to our business. Where practical we will anonymise the data we analyse. |
| To carry out other activities that are in the public interest | We may need to use personal information to verify your identity and carry out anti-money laundering checks. |
Your Right to Object – Please note that you have a right to object to processing of your personal information where that processing is carried out on the grounds of legitimate interests or public interest. If you do object:
Where relevant, we may share Intermediary personal information with:
Some of the organisations we share information with are located outside of the European Economic Area (“EEA”), including India. We’ll take steps to ensure that any such transfer of information outside of the EEA is managed to protect your privacy rights. For more information on this please see our Privacy Policy or contact us.
We maintain a retention policy to ensure we keep personal information only for as long as we reasonably need it – please see our Privacy Policy for further details.
We need to retain Intermediary personal information for the period necessary to administer the agency account and as long as is required/permitted by law in respect of any potential dispute in relation to the agency. Currently this would commonly be 7 years from the date when the agency relationship ceases.
You have various rights in relation to your personal information, including the right to:
We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than within one month after receipt of your request. In exceptional cases, we may extend this period by two months and we will tell you why. We may request proof of identification to verify your request. For more details in relation to your rights, including how to exercise them, please see our Privacy Policy or contact us using the details set out below.
If you have any questions about how we use Intermediary personal information, manage personal information within our business or if you want to exercise your rights stated above, please contact our Data Protection Officer by either emailing them at DPO@aviva.com, writing to the Data Protection Officer, Aviva, Building 12, Cherrywood Business Park, Loughlinstown, Co Dublin. D18 W25P or call us at (01) 8987000
If you have a complaint or concern about how we use your personal information please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have the right to lodge a complaint with the Office of the Data Protection Commission or any other relevant data protection authority.
Please see our Privacy Policy (available at www.aviva.ie/about-and-support/privacy/ or on request) or contact us for further details.
Aviva Life & Pensions Ireland Designated Activity Company, is a private company limited by shares, registered in Ireland No. 165970. Registered office at Building 12, Cherrywood Business Park, Loughlinstown, Co. Dublin, D18 W2P5. Tel (01) 898 7950, www.aviva.ie
Aviva Life & Pensions Ireland Designated Activity Company, trading as Aviva Life & Pensions Ireland and Friends First, is regulated by the Central Bank of Ireland.