1. Introduction
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.
Aviva Life & Pensions Ireland DAC ("Aviva", "we", "us" or "our") is the controller of the personal information collected in connection with agency and sub-agency applications and the ongoing management of Intermediary relationships.
If you have any questions about how we use your personal information, please contact the Data Protection Officer, Aviva Life & Pensions Ireland DAC, Building 12, Cherrywood Business Park, Loughlinstown, Co Dublin. D18 W25P or email DPO@aviva.com.
2. Information We Collect
We collect personal information relating to applicants, directors, partners, principals, financial advisers, sub-agents, other individuals associated with an agency relationship .
This information may include:
- identity and contact details;
- date of birth and identification details;
- employment history, qualifications and experience;
- regulatory and professional information;
- financial and tax information;
- information relevant to due diligence and suitability assessments;
- information relating to criminal convictions or offences relevant to your appointment. We recognise that information about criminal convictions is particularly sensitive and will only collect and use it where necessary for the purposes described in this notice and where permitted by applicable law.
- information regarding dietary, health or accessibility requirements where necessary to facilitate participation in webinars, events, competitions or training activities including photographs, videos; and
- emergency contact details where necessary for events.
We may obtain this information:
- directly from you;
- from the intermediary submitting the application, including where they provide details relating to directors, officers, partners, principals, advisers or sub-agents;
- from previous agency appointments and other Aviva Group companies;
- from publicly available sources, including regulatory and company registers; and
- from third-party verification and due diligence providers.
You are not obliged to provide your personal information. However, if you do not provide information that we reasonably require, we may be unable to assess an application, establish or maintain an agency relationship, or comply with our legal and regulatory obligations.
If you provide personal information about another individual, you must ensure that they have been informed that their information has been shared with us and that they have been provided with a copy of this notice.
3. How We Use Your Information
We use personal information to:
- assess applications for agency and sub-agency appointments;
- carry out due diligence, vetting and verification checks;
- establish, administer and manage agency relationships;
- administer insurance business introduced to Aviva;
- comply with legal and regulatory obligations;
- prevent, detect and investigate fraud, financial crime and other unlawful activity;
- manage disputes and protect our legal rights;
- support relationship management and improve our products, services and business operations.
- · to organise and administer webinars, events, competitions and training activities, including managing any dietary, health or accessibility requirements you may have, and to create, use and share photographs, videos, statements or other promotional content related to those activities.
- To use your emergency contact information where necessary.
4. Legal Bases for Processing
The table summarises the principal legal grounds we rely on. Not every ground applies in every case.
Legitimate interests. Where we rely on legitimate interests, we assess whether the processing is necessary and whether your rights override those interests. You have the right to object to this processing. We will consider any objection and assess whether we have compelling legitimate grounds to continue processing.
Consent. Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing carried out before consent was withdrawn.
5. Sharing Your Information
We may share personal information with:
- other Aviva Group companies;
- service providers acting on our behalf;
- professional advisers;
- regulatory, governmental and law enforcement authorities where required; and
- Your agents, nominated representatives and other parties connected with the agency relationship where appropriate.
Where personal information is transferred outside the European Economic Area, we will ensure that appropriate safeguards are in place in accordance with data protection law. Further information about these safeguards is available from our Data Protection Officer on request.
6. How Long We Keep Your Information
We retain personal information only for as long as necessary for the purposes for which it was collected and to meet legal, regulatory and business requirements.
In most cases, information relating to agency relationships will be retained for 7 years after the agency relationship ends, unless a longer period is required by law or is necessary to establish, exercise or defend legal claims.
7. Your Rights
Depending on the circumstances, you may have the following rights:
Making a request. We may ask for information to verify your identity and clarify your request. We normally respond within one month, although the law allows additional time for complex or multiple requests. We will tell you if more time is needed.
Your rights are subject to conditions and exemptions. For example, we may need to retain information to comply with a legal obligation or to establish, exercise or defend legal claims.
8. Contacting Us
If you have any questions about how we use your personal information, wish to exercise your rights, or have a concern about our processing of your information, please contact our Data Protection Officer using the details above.
If you have a complaint or concern about how we use your personal information, please contact us and we will try to resolve it as soon as possible. You may also lodge a complaint with the Data Protection Commission or another relevant data protection authority.