At WENTWORTH, we take your right to privacy seriously. It is important that you know exactly what we do with personal information that you and others provide to us, why we gather it and what it means to you.
This document is provided to you in line with our obligations under the General Data Protection Regulation (GDPR), which is effective from 25 May 2018. The GDPR together with applicable Irish requirements places enhanced accountability and transparency obligations on organisations when using your information. The GDPR gives you greater control over your personal information, including a right to object to the processing of your personal information where that processing is carried out for our business purposes.
This document explains the most important aspects of how we use your information and what rights you have in relation to your personal information. Please take time to read this document carefully and if you have any questions about how we use your information, please contact a member our Data Protection Compliance Team at the details below.
1. Who we are
Throughout this document, ‘we’, ‘us’ and ‘our’ refer to WENTWORTH. Your information is held by WENTWORTH, and the employees of WENTWORTH will have access to your information where deemed necessary to complete our contractual services. For more information about us and the services we provide, please visit our website on www.wentworth.ie.
2. The information we collect about you
We will hold:
- data to identify you, including your contact information;
- your financial details/ financial circumstances;
- your sole trade, partnership, company or personal financial information
- your financial associations; and
- information which you have consented to us using.
3. How we collect your information
We collect information: (i) you give us; (ii) information provided to us by third parties (e.g. Revenue Commissioners, financial institutions).
4. How we use your information and the legal basis
We use, and share, your data where:
- you have agreed or explicitly consented to the using of your data in a specific way (you may withdraw your consent at any time);
- use is necessary in relation to a service or a contract that you have entered into (e.g. to provide you with accounting services) or because you have asked for something to be done so you can enter into a contract with us;
- use is necessary to protect your ‘vital interests’ in exceptional circumstances; and
- use for our legitimate interests.
5. Who we share your information with
When providing our services to you, we may share your information with:
- your authorised representatives;
- third parties with whom: (i) we need to share your information to facilitate transactions you have requested, and (ii) you ask us to share your information;
- service providers who provide us with support services with your prior consent;
- statutory and regulatory bodies (e.g. Revenue and CRO); and
- pension fund administrators, trustees of collective investment undertakings and pension trustees, insurers/re-insurers, insurance bureaus (if required under our contractual agreement and with your prior consent).
6. How long we hold your data
How long we hold your data for is subject to legislation and regulatory rules we must follow, set by legislation and the type of financial services provided to you.
7. Implications of not providing your data
If you do not provide information we may not be able to:
- provide requested services to you.
We will tell you when we ask for information which is not a contractual requirement or is not needed to comply with our legal obligations and the purpose for the information request.
8. Using companies to process your information outside the European Economic Area (EEA)
In some cases, we may transfer information about you and your services to our service providers and other organisations outside the EEA (with your prior consent) if necessary to fulfil our contractual duties. We will always take steps to ensure that any transfer of information outside of the EEA is carefully managed to protect your privacy rights.
9. How to exercise your information rights including the right to object
From 25 May 2018, you will have several enhanced rights in relation to how we use your information, including the right, without undue delay, to:
- find out if we use your information, access your information and receive copies of your information;
- have inaccurate/incomplete information corrected and updated;
- object to use of your personal data for our legitimate business interests or direct marketing purposes*;
- in certain circumstances, to have your information deleted or our use of your data restricted*;
- in certain circumstances, a right not to be subject to solely automated decisions and where we make such automated decisions, a right to have a person review the decision*;
- exercise the right to data portability (i.e. obtain a transferable copy of your information we hold to transfer to another provider) *; and
- to withdraw consent at any time where processing is based on consent.
*These rights will be available from 25 May 2018.
If you wish to exercise any of your data rights, you can contact us by email to firstname.lastname@example.org, by mail to WENTWORTH, 1E North Valley Business Centre, Mallow Road, Cork or by telephoning +353 21 4217470.
If we are unable to deal with your request fully within a calendar month (due to complexity or number of requests) we may extend this period by a further two calendar months and shall explain the reason why. If you make your request electronically, we will try to provide you with the relevant information electronically.
You also have the right to complain to the Data Protection Commission or another supervisory authority. You can contact the Office of the Data Protection Commissioner at:
Telephone: +353 761 104 800 or Lo Call Number 1890 252 231
Fax: +353 57 868 4757
Postal Address: Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois.
10. How to contact us and/or our Data Protection Compliance Team
If you have questions about how we use your information, you can reach our Data Protection Compliance Team at www.wentworth.ie, by mail to 1E North Valley Business Centre, Mallow Road, Cork or by contacting +353 21 4217470.
We will update our Data Privacy Notice from time to time. Any updates will be made available and, where appropriate, notified to you by post or e-mail.