Data Protection Notice - Intermediary Personal Data

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.

Purpose

Main legal ground

Assess agency and sub-agency applications, including due diligence, vetting and verification checks and consideration of commission arrangements.

Necessary to take steps at your request before entering into an agency agreement.

 

To administer the agency account of the Intermediary in accordance with the Agency Establish, administer and manage the agency relationship, administer insurance business introduced to Aviva and perform our rights and obligations under the agency agreement, including the prevention and detection of fraud in relation to the Business conducted under the Agency T&Cs.

Necessary to perform and administer the agency agreement.

 

Comply with legal, regulatory, tax, anti-money laundering and financial crime obligations.

For compliance with a legal obligation

We may process personal information of people other than the Intermediary to administer the agency account or where necessary to organise and administer webinars, events, competitions and training activities.

Legitimate Interests (of Aviva and/or the Intermediary)

To create, use and share photographs, videos, statements or other promotional content related to webinars, events, competitions and training activities. 

Legitimate Interests (of Aviva and/or the Intermediary) and/or

Your consent where required.

To support the effective operation and improvement of our business, including relationship management, service enhancement, market research, management reporting, compliance, audit, statistical and research activities, staff training, the provision of online services and business transactions such as mergers, acquisitions, disposals or portfolio transfers. Where appropriate, we will anonymise information used for analysis and reporting purposes.

Legitimate Interests (of Aviva)

To use criminal conviction information, where relevant, to assess agency applications, carry out due diligence and vetting checks, determine appropriate commission arrangements, establish and administer the agency relationship, and perform and enforce our rights and obligations under the Agency Terms and Conditions.

Necessary to take steps at your request before entering into, and to perform and administer, an agency agreement.

 

Criminal conviction information is only processed where authorised by Irish or EU law and subject to appropriate safeguards

 

Where you choose to provide information regarding health, accessibility or dietary requirements, this may include special category personal data. We will only use this information where necessary to facilitate your participation in relevant events, training or activities and, where required, with your consent.

Your consent where required.

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:

Access

Ask whether we use your information and receive a copy.

Correction

Ask us to correct inaccurate or incomplete information.

Erasure

Ask us to delete information where there is no valid reason to keep it.

Restriction

Ask us to limit use while an issue is being considered.

Objection

Object to processing based on legitimate interests and to direct marketing.

Portability

Receive certain information in a structured, commonly used, machine-readable format or have it sent to another controller.

Automated decisions

Ask for human involvement, express your view and challenge certain solely automated decisions.

Withdraw consent

Withdraw consent where consent is the basis for processing.

Transfer safeguards

Ask for information about safeguards used for transfers outside the EEA.

Complain

Raise concerns with us or lodge a complaint with the Data Protection Commission.

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.

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.