Privacy Policy - Aviva Broker Customers
Select your product and find out how we use and safeguard your personal information.
To access your data privacy summary we need to know if you are a general insurance or life & pensions customer.
If you have a home, motor, engineering, marine or legal policy then select ‘General Insurance’.
If you have life insurance or a pension policy then select ‘Life & Pensions’.
General Insurance Aviva Broker Customers
Motor/Home/Commercial
Aviva Data Protection - Privacy Notice
We collect and use personal information about you so that we can provide you with an insurance policy that suits your insurance needs. This notice explains the most important aspects of how we use your information and what rights you have in relation to your personal information but you can get more information about the terms we use and view our full Privacy Policy at our Privacy page on our website, request a copy by writing to us at Data Protection Officer, Aviva Insurance Ireland DAC, Cherrywood Business Park, Dublin, Ireland, D18 W2P5 or call us at 01 8988000.
The data controller responsible for this personal information is Aviva Insurance Ireland DAC (“we” “us” “our”) as the insurer of the product. Additional controllers include your intermediary/broker who is responsible for the sale and distribution of the product and any applicable reinsurers.
1. Personal information we collect
Your data: The personal information we collect and use may include your name, address, telephone number and/or email address, date of birth or age, occupation, other
products you have purchased from us, insurance requirements including details about your home or vehicle, claims history, employer details (where necessary), driver licence details, bank account details or payment card details, marital status, unspent criminal convictions and for motor insurance, penalty points, Road Traffic offences, telematics data, dashboard camera video footage, on-board vehicle diagnostics information and tachograph information (commercial vehicles). For commercial insurance products, we may carry out credit searches in relation to your business.
Other people's data: As well as collecting personal information about you, we may also use personal information about other people, for example family members you wish to insure on a policy.
| Note: If you are providing information about another person we expect you to show them this data protection notice and ensure that they have given you permission to provide this information to us so that we can provide a quote. If they have any concerns please ask them to contact us in one of the ways described in the “Contacting Us” section. |
|---|
Claims data: If a claim is made we may also collect personal information about the claim from you and any relevant third parties.
| Note: 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 any claim you make. We will let you know what information is required to proceed with your application or any claim you make. |
|---|
Health data: We may need to ask for details relating to your health data or the health data of somebody else covered under your policy.
Criminal conviction data: We may ask for details relating to any unspent criminal convictions you and anybody else covered under your policy may have.
We recognise that information about health data and criminal convictions is particularly sensitive information. We will only collect and use such data as follows:
| Purpose for which it is used | Our legal basis for using it |
| Criminal conviction data is used for the purposes of providing quotes and underwriting, managing reinsurance arrangements, processing any claims you may have, fraud investigation and handling any complaints you may have. | To take steps at your request before we enter into a policy (e.g. providing a quote) and to perform our insurance policy with you and people covered under the policy. |
| Health data is used for the purposes of providing quotes and underwriting, managing reinsurance arrangements, processing any claims you may have, fraud investigation and handling any complaints you may have. | Irish Data Protection law allows us to use health data in connection with your insurance policy. |
| We may also need to use your health and/or criminal data for the purposes of establishing, exercising or defending legal rights, including in connection with advice, claims, or proceedings, and where authorised by law. | |
2. How we collect your personal information
We may collect personal information about you from:
- you;
- your named driver (if you are purchasing or renewing a motor policy);
- other people who live with you in an insured property (if you are purchasing or renewing a home insurance policy);
- your broker or intermediary;
- your employer, if relevant to your insurance cover;
- publicly available information including social media websites and online content, newspaper articles, TV, radio and other media content, court judgements;
- insurance industry databases and other commercial databases such as Cartell – we have provided more detail below on the industry databases from which we collect and share information;
- other records within the Aviva Group if you have or have had other insurance policies with or sought a quote from another Aviva company or third party claims;
- third parties involved in a claim (including a claimant, private investigators engaged by us, witnesses, solicitors and independent experts);
- when you visit one of the Aviva Group websites; and
- Insurance Ireland (insurance industry’s representative body) operate a confidential phone line (Insurance Confidential) for individuals to report suspect fraud. Information received by Insurance Ireland is shared with relevant insurers.
3. How we use your personal information
We may collect and use your information for the purposes, and on the legal basis, set out below:
| Purpose for which it is used | Our legal basis for using it |
| To provide a quote, including making a decision as to whether we can provide you with cover and at what price. | To take steps at your request prior to entering into your policy. Consent where another person provides your data to us so that we can provide them with a quote. |
| To verify your identity. | To perform the policy. To take steps at your request prior to entering into a policy. To comply with our legal obligations |
| To provide you with insurance cover and administer your insurance policy, including dealing with any queries or changes, payments, renewals and processing a cancellation of your policy. | To perform the policy. |
| To validate, investigate and/or process any claims you or another person makes in relation to your insurance policy. | To perform the policy. To comply with our legal obligations. |
| To maintain arrangements we have with reinsurers. | For our legitimate interests in managing our business. |
| For management information purposes including portfolio assessment, risk assessment, performance reporting and management reporting. | |
| For a proposed portfolio transfer, reorganisation, transfer, disposal or other transaction relating to our business. | |
| To detect and prevent fraud. | For our legitimate interests in managing our business. To perform your policy. To comply with our legal obligations |
| To comply with laws and regulations. | To comply with our legal obligations. |
4A. How we share your personal information with others
We may share your personal information:
- with the Aviva group, our agents and third parties who provide services to us, your intermediary and other insurers (either directly or via those acting for the insurer such as loss adjusters or investigators) to help us administer our products and services;
- with regulatory bodies and law enforcement bodies, including the Gardaí, e.g. if we are required to do so to comply with a relevant legal or regulatory obligation; and
- with reinsurers who provide reinsurance services to Aviva. Reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations. They will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies.
Some of the organisations we share information with are located outside of the European Economic Area, including India. These locations may not provide an adequate level of protection. We’ll always take steps to ensure that any such transfer of information is carefully managed to protect your privacy rights. For more information on this please see our Privacy Policy or contact us in one of the ways described below.
If you are purchasing a motor policy, we will also use certain information and consult certain databases as follows:
| Information used | Purpose(s) | Processing is necessary: |
| Driving Licence Number | To validate your driving licence number with the relevant authority. To validate the number of penalty points disclosed by you. | In order to take steps at your request prior to entering into the policy or for the performance of your policy. |
| Motor Third Party Liability Database | Provide information about your insurance policy for inclusion in the Motor Third Party Liability Database (MTPLD). The information contained on this database may be used by government bodies such as the Gardai and the Motor Insurers Bureau of Ireland (MIBI) for purposes permitted by law, including electronic licensing and law enforcement. |
To comply with legal obligations. |
| National Fleet Database | If you have a commercial motor fleet or motor trade policy, you will be issued with a Unique Identification Number by your insurer to upload your personal information on to the National Fleet Database. We and other government bodies such as the Gardai and MIBI can check this database for the information you have uploaded. For further information, please go to www.nfd.ie. | In order to take steps at your request prior to entering into the policy or for the performance of your policy. To comply with legal obligations. |
| National Vehicle Data File (NVDF) and IIDS Hub | When we provide you with a quote or renew your policy of motor insurance, we access the NVDF controlled by the Department of Transport, Tourism and Sport to validate: driver numbers; number of penalty points per driver. Where you provide us with an NCD PIN number, we will verify your No Claims Discount information using the IIDS Hub,where such information is made available by your previous insurer. | In order to take steps at your request prior to entering into the policy or for the performance of your policy. |
4B. How we share your personal information with others for fraud prevention
The data you provide will be used by us and shared with other insurers as well as certain statutory and other authorised bodies for anti-fraud purposes including:
- sharing information about you with other insurers (including where you are purchasing a motor insurance policy, for the purposes of validating any No Claims Discount) and public bodies including the Department of Tourism Transport and Sport, the Department of Finance and the Gardaí;
- private investigators, tracing debtors or beneficiaries, recovering debt, managing your accounts and/or insurance policies; and
- undertaking fraud searches on publicly available information as outlined above and checking the Insurance Industry claims database, Insurance Link. For more information on Insurance Link please go to www.inslink.ie. This database helps insurers check claims information and prevent fraudulent claims.
5. Credit searches
For commercial policies, we may carry out credit searches against the policyholder through third parties who provide us with credit information.
6. Automated decision making
We carry out automated decision making to decide whether we can provide insurance to you and on what terms. In particular we use an automated underwriting engine and algorithms to provide, or assist with providing, quotes including the premium that will apply to your policy of insurance, using the information we have collected. We use automated decision making as it is necessary for entering into, or performance of your policy between you as the data subject and Aviva as data controller, and other uses such as authorised by law.
7. Online information
When you visit one of the Aviva Group websites, we may record information about your computer or mobile device, including hardware and software used, general location, when and how you interact with our websites. This information is used to note your interest in our websites and improve customer journeys.
8. How long we keep your personal information for
Information submitted for a quotation may be retained by us for a period of up to 15 months from the date of the quotation. Where you purchase a product from us, information will be held for the duration of your insurance cover and for at least six years after our relationship ends in order to comply with applicable laws and regulations and for use in connection with any claims. For more information on our data retention policies please see our Privacy Policy or contact us – refer to the details in the “Contacting us” section below.
9. Your rights in relation to your personal information
You have various rights in relation to your personal information, including:
- the right to request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- ask not to be subject to automated decision making if the decision produces legal or other significant effects on you;
- to move certain data to other providers;
- Where we rely on your consent as our legal basis for use of your personal data you have a right to withdraw your consent to such use.
| Note: you have the right to object to use of personal information based on legitimate business interests. If you do object, we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims. Please note that any successful objection may prevent us assessing future claims and/or the policy may be cancelled. |
|---|
For more details in relation to your rights, including how to exercise them, please see our full Privacy Policy or contact us in one of the ways described below.
10. Contacting us
If you have any questions about how we use personal information, or if you want to exercise your rights stated above, please contact our Data Protection team by either emailing them at DPO@aviva.com, writing to the Data Protection Officer, Aviva Insurance Ireland DAC, Cherrywood Business Park, Dublin, Ireland, D18 W2P5 or call us at (01) 8988000.
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 Commissioner at any time.
Claims
Aviva Data Protection - Privacy Notice
We collect and use personal information about you so that we can process any claims you may have and any claims which may be made by a third party. This notice explains the most important aspects of how we use your information and what rights you have in relation to your personal information but you can get more information about the terms we use and view our full Privacy Policy at our Privacy page on www.aviva.ie, request a copy by writing to us at Data Protection Officer, Aviva Insurance Ireland DAC, Cherrywood Business Park, Dublin, Ireland, D18 W2P5 or call us at 01 8988000.
The data controller responsible for this personal information is Aviva Insurance Ireland DAC.
1. Personal information we collect
Your data: The personal information we collect and use may include your name, address, telephone number and/or email address, date of birth or age, occupation, details about your home or vehicle, claims history, employer details (where necessary), driver licence details, bank account details or payment card details, unspent criminal convictions, medical data and for motor insurance, penalty points, Road Traffic offences, telematics data, dashboard camera video footage, on-board vehicle diagnostics information and tachograph information (commercial vehicles).
| Note: 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 claim. We will let you know what information is required to proceed with your claim. |
|---|
We recognise that information about health data and criminal convictions is particularly sensitive information. We will only collect and use such data as follows:
| Purpose for which it is used | Our legal basis for using it |
| Criminal conviction data is used for processing any claims you may have, fraud investigation, handling any complaints you may have and managing reinsurance arrangements. | To perform our insurance policy with you and people covered under the policy. |
| Health data is used for the purposes of processing any claims you may have, fraud investigation, handling any complaints you may have and managing reinsurance arrangements. | Irish Data Protection law allows us to use health data in connection with your insurance policy. |
| We may also need to use your health and/or criminal data for the purposes of establishing, exercising or defending legal rights, including in connection with advice, claims, or proceedings, and where authorised by law. | |
2. How we collect your personal information
We may collect personal information about you from:
- you;
- your named driver;
- other people who live with you in an insured property;
- your broker or intermediary;
- your employer;
- publicly available information including social media websites and online content, newspaper articles, TV, radio and other media content, court judgements;
- insurance industry databases (such as InsuranceLink for the purposes outlined below);
- other records within the Aviva Group if you have or have had other insurance policies with or sought a quote from another Aviva company or third party claims;
- third parties involved in a claim (including a claimant, private investigators engaged by us, witnesses, solicitors, Gardaí and other agents of the state and independent experts);
- when you visit one of the Aviva Group websites;
- Insurance Ireland (insurance industry’s representative body) operate a confidential phone line (Insurance Confidential) for individuals to report suspect fraud. Information received by Insurance Ireland is shared with relevant insurers.
- The Department of Social Protection
- Motor Insurers Bureau of Ireland
- Other insurance companies
3. How we use your personal information
We may collect and use your information for the purposes, and on the legal basis, set out below:
| Purpose for which it is used | Our legal basis for using it |
| To verify your identity. | To perform the policy. To comply with our legal obligations |
| To validate, investigate and/or process any claims you or another person makes in relation to your insurance policy. | To perform the policy. To comply with our legal obligations. |
| To maintain arrangements we have with reinsurers. | For our legitimate interests in managing our business. |
| For management information purposes including portfolio assessment, risk assessment, performance reporting and management reporting. | |
| For a proposed portfolio transfer, reorganisation, transfer, disposal or other transaction relating to our business | |
| To detect and prevent fraud. | For our legitimate interests in managing our business. To perform your policy. To comply with our legal obligations. |
| To comply with laws and regulations. | To comply with our legal obligations. |
Telephone calls, may be recorded or monitored for regulatory, training and quality assurance purposes.
4A. How we share your personal information with others
We may share your personal information:
- with the Aviva group, our agents and third parties who provide services to us, your intermediary and other insurers (either directly or via those acting for the insurer such as loss adjusters or investigators) to help us administer our products and services;
- with regulatory bodies and law enforcement bodies, including the Gardaí, e.g. if we are required to do so to comply with a relevant legal or regulatory obligation;
- For motor claims, the Motor Insurers Bureau of Ireland;
- For personal injury claims, the Personal Injuries Assessment Board
- The Financial Services Ombudsman, where a complaint is made in respect of the handling or outcome of a claim;
- with reinsurers who provide reinsurance services to Aviva. Reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations. They will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies.
Some of the organisations we share information with are located outside of the European Economic Area, including India. These locations may not provide an adequate level of protection. We’ll always take steps to ensure that any such transfer of information is carefully managed to protect your privacy rights. For more information on this please see our Privacy Policy or contact us in one of the ways described below.
4B. How we share your personal information with others for fraud prevention
The data you provide will be used by us and shared with other insurers as well as certain statutory and other authorised bodies for anti-fraud purposes including:
- sharing information about you with other insurers and public bodies including the Department of Tourism Transport and Sport, and the Gardaí;
- private investigators, tracing debtors or beneficiaries, recovering debt; and
- undertaking fraud searches on publicly available information as outlined above and checking the Insurance Industry claims database, Insurance Link. For more information on Insurance Link please go to www.inslink.ie. This database helps insurers check claims information and prevent fraudulent claims.
5. We carry out profiling for the purposes of investigating fraud, identifying if further investigation is required in relation to particular claims and identifying trends in claims activity.
6. How long we keep your personal information for
Information submitted will be held for at least six years after our relationship ends in order to comply with applicable laws and regulations and for use in connection with any claims. For more information on our data retention policies please see our Privacy Policy or contact us – refer to the details in the “Contacting us” section below.
7. Your rights in relation to your personal information
You have various rights in relation to your personal information, including:
- the right to request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- to move certain data to other providers;
| Note: you have the right to object to use of personal information based on legitimate business interests. If you do object, we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims. Please note that any successful objection may prevent us assessing future claims and/or the policy may be cancelled. |
|---|
For more details in relation to your rights, including how to exercise them, please see our full Privacy Policy or contact us in one of the ways described below.
8. Contacting us
If you have any questions about how we use personal information, or if you want to exercise your rights stated above, please contact our Data Protection team by either emailing them at DPO@aviva.com, writing to the Data Protection Officer, Aviva Insurance Ireland DAC, Cherrywood Business Park, Dublin, Ireland, D18 W2P5 or call us at (01) 8988000.
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 Commissioner at any time.
Life & Pensions Aviva Broker Customers
Protection
Conversion Option
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to Applicants/Policy Owners and the life/lives to be insured. Where a section or paragraph in this Data Protection Notice refers to the Applicants/Policy Owners without referring to the life/lives to be insured then it only applies to the Applicants/Policy Owners and vice versa where a section or paragraph in this Data Protection Notice refers to the life/lives to be insured without referring to the Applicants/Policy Owners. Otherwise this Data Protection Notice and the terms “you” and “your” applies to both the Applicants/Policy Owners and life/lives to be insured.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us”, “our”) as the insurer of the product. Additional data controllers involved in the process for obtaining and maintaining insurance cover include the intermediary/financial broker (who is responsible for the sale and suitability of the product) and applicable reinsurers.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing claims and complaints. Where a conversion option is being exercised the personal information provided for the purposes of the original policy will also continue to be processed for the administration of the new (converted) policy.
We may need to ask for/process health data relevant to your policy. We recognise that information about health is particularly sensitive information. We will only collect and use such information where we need to and where it is proportionate for the purposes of the policy of insurance.
Health data includes (with the exception of the results of genetic tests) life/lives to be insured’s health data to include, existing or previous health conditions, medical history and lifestyle (e.g. smoking habits/history) and family health history. Where a conversion option is being exercised this will include the health data provided for the purposes of the original policy. If you are asked to provide health data, please do not send us the results of any genetic tests carried out on you or any other relevant person.
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 any claim you make. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. family health history of the life/lives insured, personal information about personal representatives, attorneys (under powers of attorney) and beneficiaries where polices are placed under trust.
| 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:
- already held about you within the Aviva Group (identified in our Privacy Policy), including details from previous, policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from parties relevant to claim process (e.g. claimant, private investigators engaged by us, witnesses, solicitors and independent experts);
- from publicly available information including social media websites and online content, newspaper articles, tv radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register; and
- from other insurance companies.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
(a) Personal Information (other than health data)
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether (and if so on what terms) to accept this application to include determining what premiums will apply, protection against non-disclosure of material facts and preventing or detecting fraud. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the Policy Owners in accordance with the policy conditions (a copy of which are available on request from us or the intermediary/financial broker), including to evaluate, validate and/or process any claims and complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations. |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the Policy Owners) | We may process personal information of people other than the Policy Owners to administer the policy, including processing claims and complaints for the benefit of the Policy Owners. |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as a business in assessing our reinsurance requirements and managing arrangements we have with reinsurers (these arrangements are necessary for risk transfer by insurers); managing our legal affairs including exercising our legal rights and defending claims; 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 theft and fraud. We may use your personal information to make searches of our records, if you give us false personal information or fail to disclose personal information during the application or claims process and we suspect fraud we will record this. |
| Legitimate Interests (of Aviva) | Our legitimate interests to better understand our customers and improve service enhancement and business performance, this includes customer analytics (including profiling); market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services; 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 (including to profiling) or public interest. If you do object: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
(b) Health Data
Health data is used for the purposes of set-up and underwriting of the policy of insurance, administering the policy (e.g. processing claims, handling complaints), reinsurance and/or fraud investigation in relation to the policy.
The legal basis on which we process health data in respect of the life/lives to be insured is that:
- Irish Data Protection law allows us, where necessary and proportionate, to use heath data for the purposes of a policy of insurance; and/or
- processing is necessary for the establishment, exercise or defence of legal claims.
Where we process health data for the purpose of a policy of insurance we will take suitable and specific measures to safeguard the fundamental rights and freedoms of individuals. Further information can be found in our Privacy Policy.
Automated Decisions
We may also use personal information to make automated decisions (involving an element of profiling) as necessary for entering into the policy or otherwise authorised by law. In the case of the exercise of a conversion option on standard rates (i.e. no special conditions apply to your original policy) we may use automated systems/processes, to determine what premium applies to the converted insurance cover. Premiums will be based on our standard rates (available at the time of conversion) and will reflect the smoking habits of the life/lives to be insured. For further information please see our Privacy Policy.
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. medical practitioners, lawyers, private investigators) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents and other third parties relevant to you and/or the policy, including doctors and other relevant medical practitioners, your employer, banks, lenders, policy assignees and legal advisers.
- If we are required to do so to comply with a relevant legal or regulatory obligation; with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and Department Employment Affairs and Social Protection.
- With other insurers and financial services companies, public bodies, (either directly or using shared databases) and industry bodies such as Insurance Ireland.
- With reinsurers who provide reinsurance services to Aviva and for each other. Reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations. They will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the later of the date when the customer relationship ceases or a claim in payment ceases.
Where you complete an application for but do not subsequently proceed with a policy of life insurance or cover is declined, underwriting details may be kept for a period of up to 7 years to facilitate a subsequent application or as a check against non-disclosure.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- object to our use of personal information based on legitimate interests or public interests;
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you; and
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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, Building 12, Cherrywood Business Park, Loughlinstown, Co. Dublin, D18 W2P5 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.
Term Assurance
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to Applicants/Policy Owners and the life/lives to be insured. Where a section or paragraph in this Data Protection Notice refers to the Applicants/Policy Owners without referring to the life/lives to be insured then it only applies to the Applicants/Policy Owners and vice versa where a section or paragraph in this Data Protection Notice refers to the life/lives to be insured without referring to the Applicants/Policy Owners. Otherwise this Data Protection Notice and the terms “you” and “your” applies to both the Applicants/Policy Owners and life/lives to be insured.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us”, “our”) as the insurer of the product. Additional data controllers involved in the process for obtaining and maintaining insurance cover include the intermediary/financial broker (who is responsible for the sale and suitability of the product) and applicable reinsurers.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing claims and complaints.
We may need to ask for health data relevant to your policy. We recognise that information about health is particularly sensitive information. We will only collect and use such information where we need to and where it is proportionate for the purposes of the policy of insurance.
Health data includes (with the exception of the results of genetic tests) life/lives to be insured’s health data to include, existing or previous health conditions, medical history and lifestyle (e.g. smoking habits/history) and family health history. If you are asked to provide health data, please do not send us the results of any genetic tests carried out on you or any other relevant person.
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 any claim you make. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. family health history of the life/lives insured, personal information about personal representatives, attorneys (under powers of attorney) and beneficiaries where polices are placed under trust.
| 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:
- already held about you within the Aviva Group (identified in Privacy Policy), including details from previous, policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from parties relevant to claim process (e.g. claimant, private investigators engaged by us, witnesses, solicitors and independent experts);
- from publicly available information including social media websites and online content, newspaper articles, tv, radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register;
- from other insurance companies.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
(a) Personal Information (other than health data)
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether (and if so on what terms) to accept this application to include, assessing the life/lives to be insured for underwriting/risk purposes, determining what premiums will apply, protection against non-disclosure of material facts and preventing or detecting fraud. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the Policy Owners in accordance with the policy conditions (a copy of which are available on request from us or the intermediary/financial broker), including to evaluate, validate and process any claims and complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations. |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the Policy Owners) | We may process personal information of people other than the Policy Owners, in order to administer the policy to include processing claims and complaints for the benefit of the Policy Owners. |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as a business in assessing our reinsurance requirements and managing arrangements we have with reinsurers (these arrangements are necessary for risk transfer by insurers); managing our legal affairs including exercising our legal rights and defending claims; 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 theft and fraud. We may use your personal information to make searches of our records, if you give us false personal information or fail to disclose personal information during the application or claims process and we suspect fraud we will record this. |
| Legitimate Interests (of Aviva) | Our legitimate interests to better understand our customers and improve service enhancement and business performance, this includes customer analytics (including profiling); market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services; 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 (including to profiling) or public interest. If you do object: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
(b) Health Data
Health data is used for the purposes of set-up and underwriting of the policy of insurance, administering the policy (e.g. processing claims, handling complaints), reinsurance and fraud investigation in relation to the policy.
The legal basis on which we process health data in respect of the life/lives to be insured is that:
- Irish Data Protection law allows us, where necessary and proportionate, to use heath data for the purposes of a policy of insurance; and/or
- processing is necessary for the establishment, exercise or defence of legal claims.
Where we process health data for the purpose of a policy of insurance we will take suitable and specific measures to safeguard the fundamental rights and freedoms of individuals. Further information can be found in our Privacy Policy.
Automated Decisions
We may also use personal information to make automated decisions (involving an element of profiling) as necessary for entering into the policy or otherwise authorised by law. For example we may make automated decisions, using an automated system, to decide if we can provide insurance (without going through a manual underwriting process) and if so at what premium. In particular, our automated underwriting system processes the personal and medical information provided as part of this application process (including age, smoking status, answers to our health and lifestyle questions, including family medical history), along with the amount of cover requested. We do this to calculate how much that cover will cost. Without this information we’re unable to provide a price that is relevant to your individual circumstances and needs. We regularly check the way our underwriting system works to ensure we’re being fair to our customers. For further information please see our Privacy Policy.
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. medical practitioners, lawyers, private investigators) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents and other third parties relevant to you and/or the policy, including doctors and other relevant medical practitioners, your employer, banks, lenders, policy assignees and legal advisers.
- If we are required to do so to comply with a relevant legal or regulatory obligation; with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and Department of Social Protection.
- With other insurers and financial services companies, public bodies, (either directly or using shared databases) and industry bodies such as Insurance Ireland.
- With reinsurers who provide reinsurance services to Aviva and for each other. Reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations. They will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the later of the date when the customer relationship ceases or a claim in payment ceases.
Where you complete an application for but do not subsequently proceed with a policy of life insurance or cover is declined, underwriting details may be kept for a period of up to 7 years to facilitate a subsequent application or as a check against non-disclosure.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information
- correct any mistakes on our records
- erase or restrict records where they are no longer required
- object to our use of personal information based on legitimate interests or public interests
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Personal Income Protection
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to Applicants/Policy Owners and the life/lives to be insured. Where a section or paragraph in this Data Protection Notice refers to the Applicants/Policy Owners without referring to the life/lives to be insured then it only applies to the Applicants/Policy Owners and vice versa where a section or paragraph in this Data Protection Notice refers to the life/lives to be insured without referring to the Applicants/Policy Owners. Otherwise this Data Protection Notice and the terms “you” and “your” applies to both the Applicants/Policy Owners and life/lives to be insured.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us”, “our”) as the insurer of the product. Additional data controllers involved in the process for obtaining and maintaining insurance cover include the intermediary/financial broker (who is responsible for the sale and suitability of the product) and applicable reinsurers.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing claims and complaints.
We may need to ask for health data relevant to your policy. We recognise that information about health is particularly sensitive information. We will only collect and use such information where we need to and where it is proportionate for the purposes of the policy of insurance.
Health data includes (with the exception of the results of genetic tests) life/lives to be insured’s health data to include, existing or previous health conditions, medical history and lifestyle (e.g. smoking habits/history) and family health history. If you are asked to provide health data, please do not send us the results of any genetic tests carried out on you or any other relevant person.
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 any claim you make. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. family health history of the life/lives insured, personal information about personal representatives, attorneys (under powers of attorney) and beneficiaries where polices are placed under trust.
| 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:
- already held about you within the Aviva Group (identified in Privacy Policy), including details from previous, policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from parties relevant to claim process (e.g. claimant, private investigators engaged by us, witnesses, solicitors and independent experts);
- from publicly available information including social media websites and online content, newspaper articles, tv, radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register;
- from other insurance companies.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
(a) Personal Information (other than health data)
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether (and if so on what terms) to accept this application to include, assessing the life/lives to be insured for underwriting/risk purposes, determining what premiums will apply, protection against non-disclosure of material facts and preventing or detecting fraud. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the Policy Owners in accordance with the policy conditions (a copy of which are available on request from us or the intermediary/financial broker), including to evaluate, validate and process any claims and complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations. |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the Policy Owners) | We may process personal information of people other than the Policy Owners, in order to administer the policy to include processing claims and complaints for the benefit of the Policy Owners. |
| Legitimate Interests (of Aviva and/or the Policy Owners) | To support the legitimate interest that we have as a business in assessing our reinsurance requirements and managing arrangements we have with reinsurers (these arrangements are necessary for risk transfer by insurers); managing our legal affairs including exercising our legal rights and defending claims; and managing our business effectively e.g. with third party service suppliers. |
| Legitimate Interests (of Aviva and/or the Policy Owners) | 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 theft and fraud. We may use your personal information to make searches of our records, if you give us false personal information or fail to disclose personal information during the application or claims process and we suspect fraud we will record this. |
| Legitimate Interests (of Aviva and/or the Policy Owners) | Our legitimate interests to better understand our customers and improve service enhancement and business performance, this includes customer analytics (including profiling); market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services; 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 (including to profiling) or public interest. If you do object: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
(b) Health Data
Health data is used for the purposes of set-up and underwriting of the policy of insurance, administering the policy (e.g. processing claims, handling complaints), reinsurance and fraud investigation in relation to the policy.
The legal basis on which we process health data in respect of the life/lives to be insured is that:
- Irish Data Protection law allows us, where necessary and proportionate, to use heath data for the purposes of a policy of insurance; and/or
- processing is necessary for the establishment, exercise or defence of legal claims.
Where we process health data for the purpose of a policy of insurance we will take suitable and specific measures to safeguard the fundamental rights and freedoms of individuals. Further information can be found in our Privacy Policy.
Automated Decisions
We may also use personal information to make automated decisions (involving an element of profiling) as necessary for entering into the policy or otherwise authorised by law. For example we may make automated decisions, using an automated system, to decide if we can provide insurance (without going through a manual underwriting process) and if so at what premium. In particular, our automated underwriting system processes the personal and medical information provided as part of this application process (including age, smoking status, answers to our health and lifestyle questions, including family medical history), along with the amount of cover requested. We do this to calculate how much that cover will cost. Without this information we’re unable to provide a price that is relevant to your individual circumstances and needs. We regularly check the way our underwriting system works to ensure we’re being fair to our customers. For further information please see our Privacy Policy.
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. medical practitioners, lawyers, private investigators) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents and other third parties relevant to you and/or the policy, including doctors and other relevant medical practitioners, your employer, banks, lenders, policy assignees and legal advisers.
- If we are required to do so to comply with a relevant legal or regulatory obligation; with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and Department of Social Protection.
- With other insurers and financial services companies, public bodies, (either directly or using shared databases) and industry bodies such as Insurance Ireland.
- With reinsurers who provide reinsurance services to Aviva and for each other. Reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations. They will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the later of the date when the customer relationship ceases or a claim in payment ceases.
Where you complete an application for but do not subsequently proceed with a policy of life insurance or cover is declined, underwriting details may be kept for a period of up to 7 years to facilitate a subsequent application or as a check against non-disclosure.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information
- correct any mistakes on our records
- erase or restrict records where they are no longer required
- object to our use of personal information based on legitimate interests or public interests
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Executive Income Protection
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to the life to be insured whose information is relevant to the insurance under the policy. This Data Protection Notice may also apply to the directors/signatories to this application for corporate Policy Owner or to individual Policy Owner as regards the more limited information that we will hold in respect of them (e.g. their contact details). The terms “you” and “your” are used accordingly in this Data Protection Notice.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us”, “our”) as the insurer of the product. Additional data controllers involved in the process for obtaining and maintaining insurance cover include the Policy Owner (who is employer of the life insured), intermediary/financial broker (who is responsible for the sale and suitability of the product) and applicable reinsurers.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing claims and complaints.
We may need to ask for health data relevant to your policy. We recognise that information about health is particularly sensitive information. We will only collect and use such information where we need to and where it is proportionate for the purposes of the policy of insurance.
Health data includes (with the exception of the results of genetic tests) life/lives to be insured’s health data to include, existing or previous health conditions, medical history and lifestyle (e.g. smoking habits/history) and family health history. If you are asked to provide health data, please do not send us the results of any genetic tests carried out on you or any other relevant person.
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 the application or any claim for benefit. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. family health history of the life/lives insured, personal information about personal representatives, attorneys (under powers of attorney) and beneficiaries where polices are placed under trust.
| 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:
- already held about you within the Aviva Group (identified in Privacy Policy), including details from previous, policies of insurance and claims;
- from the intermediary, financial broker or other nominated representative;
- from parties relevant to claim process (e.g. claimant, private investigators engaged by us, witnesses, solicitors and independent experts);
- from publicly available information including social media websites and online content, newspaper articles, tv, radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register;
- from other insurance companies.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
(a) Personal Information (other than health data)
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether (and if so on what terms) to accept this application to include, assessing the life/lives to be insured for underwriting/risk purposes, determining what premiums will apply, protection against non-disclosure of material facts and preventing or detecting fraud. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the Policy Owners in accordance with the policy conditions (a copy of which are available on request from us or the intermediary/financial broker), including to evaluate, validate and process any claims and complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations. |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect the life to be insured, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the Policy Owners) | We may process personal information of people other than the Policy Owners, in order to administer the policy to include processing claims and complaints for the benefit of the Policy Owners. |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as a business in assessing our reinsurance requirements and managing arrangements we have with reinsurers (these arrangements are necessary for risk transfer by insurers); managing our legal affairs including exercising our legal rights and defending claims; 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 theft and fraud. We may use your personal information to make searches of our records, if you give us false personal information or fail to disclose personal information during the application or claims process and we suspect fraud we will record this. |
| Legitimate Interests (of Aviva) | Our legitimate interests to better understand our customers and improve service enhancement and business performance, this includes customer analytics (including profiling); market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services; 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 (including to profiling) or public interest. If you do object: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
(b) Health Data
Health data is used for the purposes of set-up and underwriting of the policy of insurance, administering the policy (e.g. processing claims, handling complaints), reinsurance and fraud investigation in relation to the policy.
The legal basis on which we process health data in respect of the life/lives to be insured is that:
- Irish Data Protection law allows us, where necessary and proportionate, to use heath data for the purposes of a policy of insurance; and/or
- processing is necessary for the establishment, exercise or defence of legal claims.
Where we process health data for the purpose of a policy of insurance we will take suitable and specific measures to safeguard the fundamental rights and freedoms of individuals. Further information can be found in our Privacy Policy.
Automated Decisions
We may also use personal information to make automated decisions (involving an element of profiling) as necessary for entering into the policy or otherwise authorised by law. For example we may make automated decisions, using an automated system, to decide if we can provide insurance (without going through a manual underwriting process) and if so at what premium. In particular, our automated underwriting system processes the personal and medical information provided as part of this application process (including age, smoking status, answers to our health and lifestyle questions, including family medical history), along with the amount of cover requested. We do this to calculate how much that cover will cost. Without this information we’re unable to provide a price that is relevant to your individual circumstances and needs. We regularly check the way our underwriting system works to ensure we’re being fair to our customers. For further information please see our Privacy Policy.
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. medical practitioners, lawyers, private investigators) and third party service providers
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents and other third parties relevant to you and/or the policy, including doctors and other relevant medical practitioners, employers and legal advisers.
- If we are required to do so to comply with a relevant legal or regulatory obligation; with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and Department of Employment Affairs and Social Protection.
- With other insurers and financial services companies, public bodies, (either directly or using shared databases) and industry bodies such as Insurance Ireland.
- With reinsurers who provide reinsurance services to Aviva and for each other. Reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations. They will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the later of the date when the customer relationship ceases or a claim in payment ceases.
Where you complete an application for but do not subsequently proceed with a policy of life insurance or cover is declined, underwriting details may be kept for a period of up to 7 years to facilitate a subsequent application or as a check against non-disclosure.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information
- correct any mistakes on our records
- erase or restrict records where they are no longer required
- object to our use of personal information based on legitimate interests or public interests
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Replacement of Unit Linked Life Cover
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to Applicants/Policy Owners and the life/lives to be insured. Where a section or paragraph in this Data Protection Notice refers to the Applicants/Policy Owners without referring to the life/lives to be insured then it only applies to the Applicants/Policy Owners and vice versa where a section or paragraph in this Data Protection Notice refers to the life/lives to be insured without referring to the Applicants/Policy Owners. Otherwise this Data Protection Notice and the terms “you” and “your” applies to both the Applicants/Policy Owners and life/lives to be insured.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us”, “our”) as the insurer of the product. Additional data controllers involved in the process for obtaining and maintaining insurance cover include the intermediary/financial broker (who is responsible for the sale and suitability of the product) and applicable reinsurers.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing claims and complaints. Where replacement of unit linked life cover is being exercised the personal information provided for the purposes of the original policy will also continue to be processed for the administration of the new (converted) policy.
We may need to ask for/process health data relevant to your policy. We recognise that information about health is particularly sensitive information. We will only collect and use such information where we need to and where it is proportionate for the purposes of the policy of insurance.
Health data includes (with the exception of the results of genetic tests) life/lives to be insured’s health data to include, existing or previous health conditions, medical history and lifestyle (e.g. smoking habits/history) and family health history. Where replacement of unit linked life cover is being exercised this will include the health data provided for the purposes of the original policy. We may also use personal information about people other than you e.g. family health history of the life/lives insured, personal information about personal representatives, attorneys (under powers of attorney) and beneficiaries where polices are placed under trust. .
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 any claim you make. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. family health history of the life/lives insured, personal information about personal representatives, attorneys (under powers of attorney) and beneficiaries where polices are placed under trust.
| 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:
- already held about you within the Aviva Group (identified in our Privacy Policy), including details from previous, policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from parties relevant to claim process (e.g. claimant, private investigators engaged by us, witnesses, solicitors and independent experts);
- from publicly available information including social media websites and online content, newspaper articles, tv radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register; and
- from other insurance companies.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
(a) Personal Information (other than health data)
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether (and if so on what terms) to accept this application to include determining what premiums will apply, protection against non-disclosure of material facts and preventing or detecting fraud. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the Policy Owners in accordance with the policy conditions (a copy of which are available on request from us or the intermediary/financial broker), including to evaluate, validate and/or process any claims and complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations. |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the Policy Owners) | We may process personal information of people other than the Policy Owners to administer the policy, including processing claims and complaints for the benefit of the Policy Owners. |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as a business in assessing our reinsurance requirements and managing arrangements we have with reinsurers (these arrangements are necessary for risk transfer by insurers); managing our legal affairs including exercising our legal rights and defending claims; 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 theft and fraud. We may use your personal information to make searches of our records, if you give us false personal information or fail to disclose personal information during the application or claims process and we suspect fraud we will record this. |
| Legitimate Interests (of Aviva) | Our legitimate interests to better understand our customers and improve service enhancement and business performance, this includes customer analytics (including profiling); market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services; 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 (including to profiling) or public interest. If you do object: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
(b) Health Data
Health data is used for the purposes of set-up and underwriting of the policy of insurance, administering the policy (e.g. processing claims, handling complaints), reinsurance and/or fraud investigation in relation to the policy.
The legal basis on which we process health data in respect of the life/lives to be insured is that:
- Irish Data Protection law allows us, where necessary and proportionate, to use heath data for the purposes of a policy of insurance; and/or
- processing is necessary for the establishment, exercise or defence of legal claims.
Where we process health data for the purpose of a policy of insurance we will take suitable and specific measures to safeguard the fundamental rights and freedoms of individuals. Further information can be found in our Privacy Policy.
Automated Decisions
We may also use personal information to make automated decisions (involving an element of profiling) as necessary for entering into the policy or otherwise authorised by law. In the case of the exercise of replacement of unit linked life cover on standard rates (i.e. no special conditions apply to your original policy) we may use automated systems/processes, to determine what premium applies to the converted insurance cover. Premiums will be based on our standard rates (available at the time of replacement of unit linked life cover) and will reflect the smoking habits of the life/lives to be insured. For further information please see our Privacy Policy.
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. medical practitioners, lawyers, private investigators) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents and other third parties relevant to you and/or the policy, including doctors and other relevant medical practitioners, your employer, banks, lenders, policy assignees and legal advisers.
- If we are required to do so to comply with a relevant legal or regulatory obligation; with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and Department Employment Affairs and Social Protection.
- With other insurers and financial services companies, public bodies, (either directly or using shared databases) and industry bodies such as Insurance Ireland.
- With reinsurers who provide reinsurance services to Aviva and for each other. Reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations. They will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the later of the date when the customer relationship ceases or a claim in payment ceases.
Where you complete an application for but do not subsequently proceed with a policy of life insurance or cover is declined, underwriting details may be kept for a period of up to 7 years to facilitate a subsequent application or as a check against non-disclosure.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- object to our use of personal information based on legitimate interests or public interests;
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you; and
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
At Retirement
ARF/AMRF
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and pension products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to the Applicant/Policy Owner (referred to in this Data Protection Notice as “you” and “your”).
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we” “us” “our”) as the provider of the product. Your intermediary/financial broker (who is responsible for the sale and suitability of the product) will be an additional data controller in obtaining and maintaining the product. Where this product is being purchased by the trustees of an existing pension arrangement, in the name of the Applicant/Policy Owner, the trustees will be an additional data controller in the process for obtaining the product.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing benefits and complaints.
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 any claim you make. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g., limited personal information on trustees, administrators and qualifying fund managers of other relevant pension arrangements, your nominated representatives, personal representatives and attorneys (under powers of attorney).
| 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:
- already held about you within the Aviva Group (identified in our Privacy Policy), including details from previous policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from publicly available information including social media websites and online content, newspaper articles, tv radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register; and
- from other insurance companies, trustees, administrators or qualifying fund managers of other relevant pension arrangements.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e the insurance policy | To consider whether to accept this application and consider the related administrative and regulatory requirements e.g. eligibility for an ARF/AMRF (as applicable). |
| For the performance of a contract i.e. the insurance policy | To administer the policy for you in accordance with the policy conditions (a copy of which are available on request from us or your intermediary/financial broker), including to evaluate, validate and/or process transfers, benefit payments, complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations. |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and the policy holder) | We may process personal information of people other than the Policy Owner to administer the policy, including processing transfers, benefit payments (including death claims) and complaints for the benefit of the Policy Owner. |
| 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; 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 better understand our customers and improve service enhancement and business performance, this includes customer analytics; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services (including AvivaOnline); 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: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. lawyers) and third party service providers.
- Your intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents, nominated representatives and other third parties relevant to you and/or the policy, including other insurance companies, trustees, administrators or qualifying fund managers of other relevant pension arrangements and legal advisers.
- If we are required to do so to comply with a relevant legal or regulatory obligation: with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau and Data Protection Commission.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the date when the customer relationship ceases.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- object to our use of personal information based on legitimate interests or public interests;
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you; and
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Annuities
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and pension products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to the life/lives to be insured (who are also the annuitants) whose information is relevant to the insurance policy. This Data Protection Notice may also apply to others (e.g. where annuity is being purchased by pension scheme trustees, to the directors/signatories to this application for corporate trustee or to individual trustees) as regards the more limited information that we will hold in respect of them (e.g. as their contact details). The terms “you” and “your” are used accordingly in this Data Protection Notice.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we” “us” “our”) as the insurer of the product. Additional data controllers involved in the process for obtaining and maintaining insurance cover include the pension scheme trustees (where annuity is being purchased by them), the intermediary/financial broker (who is responsible for the sale and suitability of the product) and applicable reinsurers.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing benefits and complaints.
We may need to ask for health data relevant to your policy. We recognise that information about health is particularly sensitive information. We will only collect and use such information where we need to and where it is proportionate for the purposes of the policy of insurance.
Health data includes (with the exception of the results of genetic tests) life/lives to be insured’s health (to include, existing or previous health conditions, medical history and lifestyle (e.g. smoking habits/history). If you are providing health data, please do not send us the results of any genetic tests carried out on you or any other relevant person.
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 to pay benefits. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. personal information about personal representatives, attorneys (under powers of attorney).
| 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:
- already held about you within the Aviva Group (identified in Privacy Policy), including details from previous, policies of insurance and claims;
- from the intermediary, financial broker or other nominated representative;
- from parties relevant to claim process (e.g. claimant, private investigators engaged by us, witnesses, solicitors and independent experts);
- from publicly available information including social media websites and online content, newspaper articles, tv radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck), and (only for purposes of verifying your identity) electoral register;
- from other insurance companies.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
(a) Personal Information (other than health data)
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether (and if so on what terms) to accept this application to include: (in case of application for enhanced annuity) assessing the life to be insured for underwriting/risk purposes, determining what premiums will apply, protection against non-disclosure of material facts and preventing or detecting fraud having regard to the Revenue requirements relevant to pensions. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the annuitants in accordance with the policy conditions (a copy of which are available on request from us or intermediary/financial broker), including to: evaluate, validate and process any benefit payments and complaints and the prevention and detection of fraud in respect of the policy support Revenue requirements relevant to pensions. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations to include tax laws |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the annuitants)
| We may process personal information of people other than the annuitants, in order to administer the policy to include processing claims and complaints for the benefit of the annuitants. |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as business in our reinsurance requirements and managing arrangements we have with reinsurers (these arrangements are necessary for risk transfer by insurers); managing our legal affairs including exercising our legal rights and defending claims; 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 theft and fraud. We may use your personal information to make searches of our records, if you give us false personal information or fail to disclose personal information during the application and we suspect fraud we will record this. |
| Legitimate Interests (of Aviva) | Our legitimate interests to better understand our customers and improve service enhancement and business performance, this includes customer analytics (including profiling); market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services ; 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 (including to profiling) or public interest. If you do object: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
(b) Health Data
Health data is used for the purposes of set-up and underwriting of a policy of insurance, administering a policy (e.g. processing claims, handling complaints), reinsurance and fraud investigation in relation to the policy.
The legal basis on which we process health data in respect of the life/lives to be insured is that:
- Irish Data Protection law allows us where necessary and proportionate to use heath data for the purposes of a policy of insurance; and/or
- processing is necessary for the establishment, exercise or defence of legal claims.
Where we process health data for the purpose of a policy of insurance we will take suitable and specific measures to safeguard the fundamental rights and freedoms of individuals. Further information can be found in our Privacy Policy.
Automated Decisions
We may also use personal information to make automated decisions (involving an element of profiling) as necessary for entering into the policy or otherwise authorised by law. Our process to decide what annuity rates (with key factor being age) apply to annuity applications is automated and in the case of enhanced annuity applications takes account of the answers to our health and lifestyle questionnaire i.e. health data. For further information please see our Privacy Policy.
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. medical practitioners, lawyers, private investigators) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents and other third parties relevant to you and/or the policy, including doctors and other relevant medical practitioners, employer, previous employers, other insurance companies, trustees, administrators and other pension providers.
- If appropriate with regard to relevant legal/tax regulatory obligations and Revenue requirements relevant to pensions: with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and Department of Employment Affairs and Social Protection.
- With other insurers and financial services companies, public bodies, (either directly or using shared databases) and industry bodies such as Insurance Ireland.
- With reinsurers who provide reinsurance services to Aviva and for each other. Reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations. They will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the later of the date when the customer relationship ceases or a claim in payment ceases.
Where you complete an application for but do not subsequently proceed with a policy of life insurance, details may be kept for a period of up to 6 years to facilitate a subsequent application or as a check against non-disclosure.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information
- correct any mistakes on our records
- erase or restrict records where they are no longer required
- object to our use of personal information based on legitimate interests or public interests
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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/privacy or on request) or contact us for further details.
Savings & Investments
Investment Bond
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and investment products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to Applicants/Policy Owners and the life/lives to be insured. Where a section or paragraph in this Data Protection Notice refers to the Applicants/Policy Owners without referring to the life/lives to be insured then it only applies to the Applicants/Policy Owners and vice versa where a section or paragraph in this Data Protection Notice refers to the life/lives to be insured without referring to the Applicants/Policy Owners. Otherwise this Data Protection Notice and the terms “you” and “your” applies to both the Applicants/Policy Owners and life/lives to be insured.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we” “us” “our”) as the provider of the product. Your intermediary/financial broker (who is responsible for the sale and suitability of the product) will be an additional data controller in obtaining and maintaining the product.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing payment of benefits and complaints.
We are obliged to collect information on the tax residency of each Applicant/Policy Owner (and where relevant controlling persons). We will ask for details of tax residency and tax identification numbers (where applicable) and will record this on our records (please see section 4 ‘Who we share your information with’ for further details). As part of our Anti-Money Laundering obligations, we must also receive information on source of funds, source of wealth, income and occupation.
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 any claim you make.
We may also use personal information about people other than you e.g. tax status of any relevant controlling persons, limited personal information on your nominated representatives, personal representatives, attorneys (under powers of attorney) and beneficiaries where the policy is under trust.
| 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:
- already held about you within the Aviva Group (identified in our Privacy Policy), including details from previous policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from publicly available information including social media websites and online content, newspaper articles, tv radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register; and
- from other insurance and financial services companies.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether to accept this application and consider the related administrative requirements e.g. product eligibility. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the Policy Owners in accordance with the policy conditions (a copy of which are available on request from us or the intermediary/financial broker), including to evaluate, validate and/or process benefit payments, complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations, including Anti-Money Laundering, CRS (Common Reporting Standards), AEOI (Automatic Exchange of Information) and FATCA (Foreign Account Tax Compliance Act). |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the Policy Owners) | We may process personal information of people other than the Policy Owners to administer the policy, including processing benefit paymets and complaints for the benefit of the Policy Owners |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as business in managing our legal affairs including exercising our legal rights and defending claims; 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 better understand our customers and improve service enhancement and business performance, this includes customer analytics; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services (including AvivaOnline); 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. |
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. lawyers) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents, nominated representatives and other third parties relevant to you and/or the policy, including banks, lenders, policy assignees and legal advisers.
- If we are required to do so to comply with a relevant legal or regulatory obligation: with regulatory bodies, law enforcement bodies, government departments including Revenue Commissioners/ Inspector of Taxes, Criminal Assets Bureau, Central Bank of Ireland, Financial Services and Pensions Ombudsman, Gardaí and Data Protection Commission.
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.
Sharing of tax information: Customer Information Notice
There is an obligation on financial institutions including Aviva, to collect and report certain information about the tax residence of Policy Owners (and where relevant controlling persons). In certain circumstances, we are required by law to provide policy information to the Irish Revenue Commissioners who may, in turn, share this information with tax authorities in applicable jurisdictions. Ireland has and will be entering into a number of exchange of information agreements to share tax information, where applicable, with the tax authorities in other territories.
We are obliged to ask for details of tax residency and tax identification numbers (where applicable) and will record this on our records. In certain circumstances we may be legally required to share the information listed below with the Irish Revenue Commissioners and they may transfer that information to the applicable country:
- Name, address, jurisdiction of tax residence, Tax Identification Number (TIN or PPSN) and date of birth.
- Policy number and that the policy is held with Aviva.
- The value of the policy at the end of the year or at the date it was closed (and date of closure).
- The gross amount of interest, dividends, proceeds from sale or redemption of financial assets or other amounts paid or credited to the controlling person or policy during the year.
- Where relevant, details of certain controlling persons.
Only information that is legally required to be reported to the Irish Revenue Commissioners will be included in the annual return that we may be obliged to submit. The Irish Revenue Commissioners will only exchange that information with another jurisdiction where there is a legal agreement to do so. In accordance with applicable exchange of information agreements, Irish tax authorities will also begin to receive information from tax authorities of other territories about non-Irish accounts held by Irish tax residents. For further information on the cross-border sharing of tax information by tax administrations please refer to the Irish Revenue website at https://www.revenue.ie/en/business/aeoi/index.html.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the date when the customer relationship ceases.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- object to our use of personal information based on legitimate interests or public interests;
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you; and
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Regular Saver
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and investment products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to Applicants/Policy Owners and the life/lives to be insured. Where a section or paragraph in this Data Protection Notice refers to the Applicants/Policy Owners without referring to the life/lives to be insured then it only applies to the Applicants/Policy Owners and vice versa where a section or paragraph in this Data Protection Notice refers to the life/lives to be insured without referring to the Applicants/Policy Owners. Otherwise this Data Protection Notice and the terms “you” and “your” applies to both the Applicants/Policy Owners and life/lives to be insured.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we” “us” “our”) as the provider of the product. Your intermediary/financial broker (who is responsible for the sale and suitability of the product) will be an additional data controller in obtaining and maintaining the product.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing payment of benefits and complaints.
We are obliged to collect information on the tax residency of each Applicant/Policy Owner (and where relevant controlling persons). We will ask for details of tax residency and tax identification numbers (where applicable) and will record this on our records (please see section 4 ‘Who we share your information with’ for further details). As part of our Anti-Money Laundering obligations, we must also receive information on source of funds, source of wealth, income and occupation.
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 any claim you make.
We may also use personal information about people other than you e.g. tax status of any relevant controlling persons, limited personal information on your nominated representatives, personal representatives, attorneys (under powers of attorney) and beneficiaries where the policy is under trust.
| 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:
- already held about you within the Aviva Group (identified in our Privacy Policy), including details from previous policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from publicly available information including social media websites and online content, newspaper articles, tv radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register; and
- from other insurance and financial services companies.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy
| To consider whether to accept this application and consider the related administrative requirements e.g. product eligibility. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the Policy Owners in accordance with the policy conditions (a copy of which are available on request from us or the intermediary/financial broker), including to evaluate, validate and/or process benefit payments, complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations, including Anti-Money Laundering, CRS (Common Reporting Standards), AEOI (Automatic Exchange of Information) and FATCA (Foreign Account Tax Compliance Act). |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the Policy Owners) | We may process personal information of people other than the Policy Owners to administer the policy, including processing benefit payments and complaints for the benefit of the Policy Owners. |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as business in managing our legal affairs including exercising our legal rights and defending claims; 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 better understand our customers and improve service enhancement and business performance, this includes customer analytics; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services (including AvivaOnline); 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: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. lawyers) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents, nominated representatives and other third parties relevant to you and/or the policy, including banks, lenders, policy assignees and legal advisers.
- If we are required to do so to comply with a relevant legal or regulatory obligation: with regulatory bodies, law enforcement bodies, government departments including Revenue Commissioners/ Inspector of Taxes, Criminal Assets Bureau, Central Bank of Ireland, Financial Services and Pensions Ombudsman, Gardaí and Data Protection Commission.
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.
Sharing of tax information: Customer Information Notice
There is an obligation on financial institutions including Aviva, to collect and report certain information about the tax residence of Policy Owners (and where relevant controlling persons). In certain circumstances, we are required by law to provide policy information to the Irish Revenue Commissioners who may, in turn, share this information with tax authorities in applicable jurisdictions. Ireland has and will be entering into a number of exchange of information agreements to share tax information, where applicable, with the tax authorities in other territories.
We are obliged to ask for details of tax residency and tax identification numbers (where applicable) and will record this on our records. In certain circumstances we may be legally required to share the information listed below with the Irish Revenue Commissioners and they may transfer that information to the applicable country:
- Name, address, jurisdiction of tax residence, Tax Identification Number (TIN or PPSN) and date of birth.
- Policy number and that the policy is held with Aviva.
- The value of the policy at the end of the year or at the date it was closed (and date of closure).
- The gross amount of interest, dividends, proceeds from sale or redemption of financial assets or other amounts paid or credited to the controlling person or policy during the year.
- Where relevant, details of certain controlling persons.
Only information that is legally required to be reported to the Irish Revenue Commissioners will be included in the annual return that we may be obliged to submit. The Irish Revenue Commissioners will only exchange that information with another jurisdiction where there is a legal agreement to do so. In accordance with applicable exchange of information agreements, Irish tax authorities will also begin to receive information from tax authorities of other territories about non-Irish accounts held by Irish tax residents. For further information on the cross-border sharing of tax information by tax administrations please refer to the Irish Revenue website at https://www.revenue.ie/en/business/aeoi/index.html.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the date when the customer relationship ceases.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- object to our use of personal information based on legitimate interests or public interests;
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you; and
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Corporate Investment Bond
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and investment products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to Applicants/Policy Owners and the life/lives to be insured. Where a section or paragraph in this Data Protection Notice refers to the Applicants/Policy Owners without referring to the life/lives to be insured then it only applies to the Applicants/Policy Owners and vice versa where a section or paragraph in this Data Protection Notice refers to the life/lives to be insured without referring to the Applicants/Policy Owners. Otherwise this Data Protection Notice and the terms “you” and “your” applies to both the Applicants/Policy Owners and life/lives to be insured.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we” “us” “our”) as the provider of the product. Your intermediary/financial broker (who is responsible for the sale and suitability of the product) will be an additional data controller in obtaining and maintaining the product.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing payment of benefits and complaints.
We are obliged to collect information on the tax residency of each Applicant/Policy Owner (and where relevant controlling persons). We will ask for details of tax residency and tax identification numbers (where applicable) and will record this on our records (please see section 4 ‘Who we share your information with’ for further details). As part of our Anti-Money Laundering obligations, we must also receive information on source of funds, source of wealth, income and occupation.
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 any claim you make.
We may also use personal information about people other than you e.g. tax status of any relevant controlling persons, limited personal information on your nominated representatives, personal representatives, attorneys (under powers of attorney) and beneficiaries where the policy is under trust.
| 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:
- already held about you within the Aviva Group (identified in our Privacy Policy), including details from previous policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from publicly available information including social media websites and online content, newspaper articles, tv radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register; and
- from other insurance and financial services companies.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether to accept this application and consider the related administrative requirements e.g. product eligibility. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the Policy Owners in accordance with the policy conditions (a copy of which are available on request from us or the intermediary/financial broker), including to evaluate, validate and/or process benefit payments, complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations, including Anti-Money Laundering, CRS (Common Reporting Standards), AEOI (Automatic Exchange of Information) and FATCA (Foreign Account Tax Compliance Act). |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the Policy Owners) | We may process personal information of people other than the Policy Owners to administer the policy, including processing benefit payments and complaints for the benefit of the Policy Owners. |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as business in managing our legal affairs including exercising our legal rights and defending claims; 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 better understand our customers and improve service enhancement and business performance, this includes customer analytics; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services (including AvivaOnline); 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: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. lawyers) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents, nominated representatives and other third parties relevant to you and/or the policy, including banks, lenders, policy assignees and legal advisers.
- If we are required to do so to comply with a relevant legal or regulatory obligation: with regulatory bodies, law enforcement bodies, government departments including Revenue Commissioners/ Inspector of Taxes, Criminal Assets Bureau, Central Bank of Ireland, Financial Services and Pensions Ombudsman, Gardaí and Data Protection Commission.
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.
Sharing of tax information: Customer Information Notice
There is an obligation on financial institutions including Aviva, to collect and report certain information about the tax residence of Policy Owners (and where relevant controlling persons). In certain circumstances, we are required by law to provide policy information to the Irish Revenue Commissioners who may, in turn, share this information with tax authorities in applicable jurisdictions. Ireland has and will be entering into a number of exchange of information agreements to share tax information, where applicable, with the tax authorities in other territories.
We are obliged to ask for details of tax residency and tax identification numbers (where applicable) and will record this on our records. In certain circumstances we may be legally required to share the information listed below with the Irish Revenue Commissioners and they may transfer that information to the applicable country:
- Name, address, jurisdiction of tax residence, Tax Identification Number (TIN or PPSN) and date of birth.
- Policy number and that the policy is held with Aviva.
- The value of the policy at the end of the year or at the date it was closed (and date of closure).
- The gross amount of interest, dividends, proceeds from sale or redemption of financial assets or other amounts paid or credited to the controlling person or policy during the year.
- Where relevant, details of certain controlling persons.
Only information that is legally required to be reported to the Irish Revenue Commissioners will be included in the annual return that we may be obliged to submit. The Irish Revenue Commissioners will only exchange that information with another jurisdiction where there is a legal agreement to do so. In accordance with applicable exchange of information agreements, Irish tax authorities will also begin to receive information from tax authorities of other territories about non-Irish accounts held by Irish tax residents. For further information on the cross-border sharing of tax information by tax administrations please refer to the Irish Revenue website at https://www.revenue.ie/en/business/aeoi/index.html.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the date when the customer relationship ceases.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- object to our use of personal information based on legitimate interests or public interests;
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you; and
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Corporate Regular Saver
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and investment products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to Applicants/Policy Owners and the life/lives to be insured. Where a section or paragraph in this Data Protection Notice refers to the Applicants/Policy Owners without referring to the life/lives to be insured then it only applies to the Applicants/Policy Owners and vice versa where a section or paragraph in this Data Protection Notice refers to the life/lives to be insured without referring to the Applicants/Policy Owners. Otherwise this Data Protection Notice and the terms “you” and “your” applies to both the Applicants/Policy Owners and life/lives to be insured.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we” “us” “our”) as the provider of the product. Your intermediary/financial broker (who is responsible for the sale and suitability of the product) will be an additional data controller in obtaining and maintaining the product.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing payment of benefits and complaints.
We are obliged to collect information on the tax residency of each Applicant/Policy Owner (and where relevant controlling persons). We will ask for details of tax residency and tax identification numbers (where applicable) and will record this on our records (please see section 4 ‘Who we share your information with’ for further details). As part of our Anti-Money Laundering obligations, we must also receive information on source of funds, source of wealth, income and occupation.
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 any claim you make.
We may also use personal information about people other than you e.g. tax status of any relevant controlling persons, limited personal information on your nominated representatives, personal representatives, attorneys (under powers of attorney) and beneficiaries where the policy is under trust.
| 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:
- already held about you within the Aviva Group (identified in our Privacy Policy), including details from previous policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from publicly available information including social media websites and online content, newspaper articles, tv radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register; and
- from other insurance and financial services companies.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy
| To consider whether to accept this application and consider the related administrative requirements e.g. product eligibility. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the Policy Owners in accordance with the policy conditions (a copy of which are available on request from us or the intermediary/financial broker), including to evaluate, validate and/or process benefit payments, complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations, including Anti-Money Laundering, CRS (Common Reporting Standards), AEOI (Automatic Exchange of Information) and FATCA (Foreign Account Tax Compliance Act). |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the Policy Owners) | We may process personal information of people other than the Policy Owners to administer the policy, including processing benefit payments and complaints for the benefit of the Policy Owners. |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as business in
managing our legal affairs including exercising our legal rights and defending claims; 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 better understand our customers and improve service enhancement and business performance, this includes
customer analytics; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services (including AvivaOnline); 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: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. lawyers) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents, nominated representatives and other third parties relevant to you and/or the policy, including banks, lenders, policy assignees and legal advisers.
- If we are required to do so to comply with a relevant legal or regulatory obligation: with regulatory bodies, law enforcement bodies, government departments including Revenue Commissioners/ Inspector of Taxes, Criminal Assets Bureau, Central Bank of Ireland, Financial Services and Pensions Ombudsman, Gardaí and Data Protection Commission.
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.
Sharing of tax information: Customer Information Notice
There is an obligation on financial institutions including Aviva, to collect and report certain information about the tax residence of Policy Owners (and where relevant controlling persons). In certain circumstances, we are required by law to provide policy information to the Irish Revenue Commissioners who may, in turn, share this information with tax authorities in applicable jurisdictions. Ireland has and will be entering into a number of exchange of information agreements to share tax information, where applicable, with the tax authorities in other territories.
We are obliged to ask for details of tax residency and tax identification numbers (where applicable) and will record this on our records. In certain circumstances we may be legally required to share the information listed below with the Irish Revenue Commissioners and they may transfer that information to the applicable country:
- Name, address, jurisdiction of tax residence, Tax Identification Number (TIN or PPSN) and date of birth.
- Policy number and that the policy is held with Aviva.
- The value of the policy at the end of the year or at the date it was closed (and date of closure).
- The gross amount of interest, dividends, proceeds from sale or redemption of financial assets or other amounts paid or credited to the controlling person or policy during the year.
- Where relevant, details of certain controlling persons.
Only information that is legally required to be reported to the Irish Revenue Commissioners will be included in the annual return that we may be obliged to submit. The Irish Revenue Commissioners will only exchange that information with another jurisdiction where there is a legal agreement to do so. In accordance with applicable exchange of information agreements, Irish tax authorities will also begin to receive information from tax authorities of other territories about non-Irish accounts held by Irish tax residents. For further information on the cross-border sharing of tax information by tax administrations please refer to the Irish Revenue website at http://www.revenue.ie/en/business/aeoi/index.html.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the date when the customer relationship ceases.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- object to our use of personal information based on legitimate interests or public interests;
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you; and
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Individual Pensions
Personal Pension Plan
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and pension products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to the Applicant/Policy Owner (referred to in this Data Protection Notice as “you” and “your”).
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us”, “our”) as the provider of the product. Your intermediary/financial broker (who is responsible for the sale and suitability of the product) will be an additional data controller in obtaining and maintaining the product.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing benefits and complaints.
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 any claim you make. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. limited personal information on administrators/managers of a relevant pension arrangement, your nominated representatives, personal representatives and your attorneys (under powers of attorney).
| 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:
- already held about you within the Aviva Group (identified in our Privacy Policy), including details from previous policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from publicly available information including social media websites and online content, newspaper articles, tv radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register; and
- from other insurance companies and other pension providers.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether to accept this application and consider the related administrative and regulatory requirements e.g. eligibility for a personal pension. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for you in accordance with the policy conditions (a copy of which are available on request from us or your intermediary/financial broker), including to evaluate, validate and/or process transfers, benefit payments, policy options and complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations. |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the Policy Owner) | We may process personal information of people other than the Policy Owner to administer the policy, including processing transfers, benefit payments, policy options and complaints for the benefit of the Policy Owner. |
| 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; 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 better understand our customers and improve service enhancement and business performance, this includes customer analytics; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services (including AvivaOnline); 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: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. lawyers) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents, nominated representatives and other third parties relevant to you and/or the policy, including your legal advisers, other insurance companies and relevant pension providers.
- If we are required to do so to comply with a relevant legal or regulatory obligation: with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and National Treasury Management Agency.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the date when the customer relationship ceases.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- object to our use of personal information based on legitimate interests or public interests;
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you; and
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Executive Pension Plan
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and pension products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to the life to be insured whose information is relevant to the insurance under the policy and the administration of the Executive Pension Plan of which the life insured is a member. This Data Protection Notice also applies (as regards the more limited information that we may hold in respect of them e.g. their contact details) to:
- signatories to the application for the policy
- directors of corporate trustee/employer of the Executive Pension Plan
- individual trustees
- the employer if a sole trader or partnership.
The terms “you” and “your” are used accordingly in this Data Protection Notice.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we” “us” “our”), the insurer of the policy (issued to the trustees of the Executive Pension Plan as Policy Owners). Additional data controllers involved in the policy and the Executive Pension Plan include:
- trustees of the Executive Pension Plan
- employer of the Executive Pension Plan
- intermediary/financial broker (who is responsible for the sale and suitability of the product).
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to the application for the policy and the administration of the policy and the Executive Pension Plan, to include processing claims and complaints.
We may need to ask for health data relevant to your policy. We recognise that information about health is particularly sensitive information. We will only collect and use such information where we need to and where it is proportionate for the purposes of the policy of insurance.
Health data includes (with the exception of the results of genetic tests) life to be insured’s health data to include, existing or previous health conditions, medical history and lifestyle (e.g. smoking habits/history) and family health history. If you are asked to provide health data, please do not send us the results of any genetic tests carried out on you or any other relevant person.
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 the application or any claim for benefit. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. family health history of the life insured, (if benefits payable to them) spouse/dependants of member the Executive Pension Plan.
| 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:
- already held about you within the Aviva Group (identified in Privacy Policy) , including details from previous, policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from parties relevant to claim process (e.g. claimant, private investigators engaged by us, witnesses, solicitors and independent experts);
- from publicly available information including social media websites and online content, newspaper articles, tv, radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck), and (only for purposes of verifying your identity) electoral register;
- from other insurance companies, trustees of other pension schemes, previous employers, other pension providers.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
(a) Personal Information (other than health data)
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether (and if so on what terms) to accept the application for the policy to include: assessing the life to be insured for underwriting/risk purposes, determining what premiums will apply, protection against non-disclosure of material facts and preventing or detecting fraud having regard to the related administrative and regulatory requirements e.g. Revenue approval of the Executive Pension Plan. |
| For the performance of a contract i.e. the insurance policy and related administration of Executive Pension Plan | To administer the policy for the Policy Owners (the trustees of the Executive Pension Plan) in accordance with the policy conditions (a copy of which are available on request from us or intermediary/financial broker), including to: evaluate, validate and process any claims and complaints and the prevention and detection of fraud in respect of the policy support the administration of the Executive Pension Plan e.g. arrange Revenue approval of the Executive Pension Plan address Pension Act requirements e.g. disclosure other statutory requirements e.g. pension adjustment orders. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations to include those (e.g. annual benefit statements, annual reports) as Registered Administrator of the Executive Pension Plan. |
| Legitimate Interests (of Aviva and/or the Policy Owners and/or the member of the Executive Pension Plan) | We may process personal information of people other than the Policy Owners, in order to administer the policy and support the administration of the Executive Pension Plan. This processing will also be in the legitimate interests of the Policy Owners in the conduct of their business and/or the member of the Executive Pension Plan in having access to and the benefit of the Executive Pension Plan. |
| To protect your vital interests: | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you e.g. liaise with the Pensions Authority and/or Revenue Commissioners if trustee/employer in liquidation. |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as a business in assessing our reinsurance requirements and managing arrangements we have with reinsurers (these arrangements are necessary for risk transfer by insurers); managing our legal affairs including exercising our legal rights and defending claims; 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 theft and fraud. We may use your personal information to make searches of our records, if you give us false personal information or fail to disclose personal information during the application or claims process and we suspect fraud we will record this. |
| Legitimate Interests (of Aviva) | Our legitimate interests to better understand our customers and improve service enhancement and business performance, this includes customer analytics (including profiling); market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services; 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 (including to profiling) or public interest. If you do object: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
b) Health Data
Health data is used for the purposes of set-up and underwriting of policy of insurance, administering policy (e.g. processing claims, handling complaints), reinsurance or fraud investigation in relation to the policy.
The legal basis on which we process health data in respect of the life to be insured is that:
- Irish Data Protection law allows us where necessary and proportionate to use heath data for the purposes of a policy of insurance; and/or
- processing is necessary for the establishment, exercise or defence of legal claims.
Where we process health data for the purpose of a policy of insurance we will take suitable and specific measures to safeguard the fundamental rights and freedoms of individuals. Further information can be found in our Privacy Policy.
Automated Decisions
We may also use personal information to make automated decisions (involving an element of profiling) as necessary for entering into the policy or otherwise authorised by law. For example we may make automated decisions, using an automated system, to decide if we can provide insurance (without going through a manual underwriting process) and if so at what premium. In particular, our automated underwriting system processes the personal and medical information provided as part of the application for the policy process (including age, smoking status, answers to our health and lifestyle questions, including family medical history), along with the amount of cover requested. We do this to calculate how much that cover will cost. Without this information we’re unable to provide a price that is relevant to your individual circumstances and needs. We regularly check the way our underwriting system works to ensure we’re being fair to our customers. For further information please see our Privacy Policy.
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. medical practitioners, lawyers, private investigators) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents and other third parties relevant to you and/or the policy, including doctors and other relevant medical practitioners, employer, previous employers, other insurance companies, trustees, administrators and other pension providers.
- If appropriate with regard to relevant legal/tax regulatory obligations and Revenue approval of the Executive Pension Plan: with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Pensions Authority, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and Department of Employment Affairs and Social Protection.
- With other insurers and financial services companies, public bodies, (either directly or using shared databases) and industry bodies such as Insurance Ireland.
- With reinsurers who provide reinsurance services to Aviva and for each other. Reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations. They will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and support the administration of the Executive Pension Plan and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the later of the date when the customer relationship ceases or a claim in payment ceases.
Where you complete an application for but do not subsequently proceed with a policy of life insurance or cover is declined, underwriting details may be kept for a period of up to 6 years to facilitate a subsequent application or as a check against non-disclosure.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information
- correct any mistakes on our records
- erase or restrict records where they are no longer required
- object to our use of personal information based on legitimate interests or public interests
- asking not to be subject to solely automated decision making if the decision produces legal or other significant effects on you
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Retirement Bond
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and pension products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to Applicants (i.e. the Trustees of the Existing Scheme as identified in this Application) and the Policy Owner (i.e. the member of the Existing Scheme and ultimate retirement bond owner). The terms “you” and “your” are used accordingly in this Data Protection Notice.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us”, “our”) as the provider of the product. Your intermediary/financial broker (who is responsible for the sale and suitability of the product) will be an additional data controller for obtaining and maintaining the product. The Trustees of the Existing Scheme (as identified in this Application) will also be an additional data controller for the process of obtaining the product.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing policy options, benefit payments and complaints.
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 any claim you make.
We may also use personal information about people other than you e.g. limited personal information on your employer (or past employer), nominated representatives, personal representatives and attorneys (under powers of attorney).
| If you are providing personal information about another person, unless the provision of such information proves impossible, 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:
- already held about you within the Aviva Group (identified in our Privacy Policy), including details from previous, policies of insurance and claims;
- from your intermediary, financial broker or other nominated representatives or agents;
- from publicly available information including social media websites and online content, newspaper articles, tv radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register; and
- from other third parties relevant to you and/or the policy, including your employer (or past employer), other insurance companies, trustees, administrators and providers of relevant pension arrangements.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether to accept this application and consider the related administrative and regulatory requirements e.g. eligibility for a retirement bond. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the Policy Owner in accordance with the policy conditions (a copy of which are available on request from us or the intermediary/financial broker), including to evaluate, validate and/or process transfers, benefit payments, policy options and complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations. |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva, the Applicants and/or the Policy Owner) |
We may process personal information of the Policy Owner at the request of the Applicant only (e.g. where a Trustee is requesting a policy to be set up without consent). We may also process personal information of people other than you to administer the policy including processing transfers, policy options, benefit payments and complaints for the benefit of the Policy Owner |
| 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; 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 better understand our customers and improve service enhancement and business performance, this includes customer analytics; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services (including AvivaOnline); 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: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. lawyers) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents, nominated representatives and other third parties relevant to you and/or the policy, including your employer (or past employer), other insurance companies, trustees, administrators and providers of relevant pension arrangements.
- If we are required to do so to comply with a relevant legal or regulatory obligation; with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau and Data Protection Commission and National Treasury Management Agency.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the date when the customer relationship ceases.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- object to our use of personal information based on legitimate interests or public interests;
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you; and
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Personal Pension Term Assurance
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and pension products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to the Applicant/Policy Owner/life to be insured (also referred to in this Data Protection Notice as “you” and “your”.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us”, “our”) as the insurer of the product. Additional data controllers involved in the process for obtaining and maintaining insurance cover include the intermediary/financial broker (who is responsible for the sale and suitability of the product) and applicable reinsurers.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing claims and complaints.
We may need to ask for health data relevant to your policy. We recognise that information about health is particularly sensitive information. We will only collect and use such information where we need to and where it is proportionate for the purposes of the policy of insurance.
Health data includes (with the exception of the results of genetic tests) existing or previous health conditions, medical history and lifestyle (e.g. smoking habits/history) and family health history. If you are asked to provide health data, please do not send us the results of any genetic tests carried out on you or any other relevant person.
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 any claim you make. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. your family health history, limited personal information about your nominated representatives, personal representatives and attorneys (under powers of attorney).
| 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:
- already held about you within the Aviva Group (identified in our Privacy Policy), including details from previous, policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from parties relevant to claim process (e.g. claimant, private investigators engaged by us, witnesses, solicitors and independent experts);
- from publicly available information including social media websites and online content, newspaper articles, tv, radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register; and
- from other insurance companies and other pension providers.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
(a) Personal Information (other than health data)
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether (and if so on what terms) to accept this application to include, assessing the life to be insured for underwriting/risk purposes, determining what premiums will apply, protection against non-disclosure of material facts and preventing or detecting fraud. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for you in accordance with the policy conditions (a copy of which are available on request from us or the intermediary/financial broker), including to evaluate, validate and process any claims and complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations. |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the Policy Owner) | We may process personal information of people other than the Policy Owner to administer the policy, including processing claims and complaints for the benefit of the Policy Owner. |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as a business in assessing our reinsurance requirements and managing arrangements we have with reinsurers (these arrangements are necessary for risk transfer by insurers); managing our legal affairs including exercising our legal rights and defending claims; 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 theft and fraud. We may use your personal information to make searches of our records, if you give us false personal information or fail to disclose personal information during the application or claims process and we suspect fraud we will record this. |
| Legitimate Interests (of Aviva) | Our legitimate interests to better understand our customers and improve service enhancement and business performance, this includes customer analytics (including profiling); market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services; 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 (including to profiling) or public interest. If you do object: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
(b) Health Data
Health data is used for the purposes of set-up and underwriting of the policy of insurance, administering the policy (e.g. processing claims, handling complaints), reinsurance and/or fraud investigation in relation to the policy.
The legal basis on which we process health data in respect of the policy is that:
- Irish Data Protection law allows us, where necessary and proportionate, to use heath data for the purposes of a policy of insurance; and/or
- processing is necessary for the establishment, exercise or defence of legal claims.
Where we process health data for the purpose of a policy of insurance we will take suitable and specific measures to safeguard the fundamental rights and freedoms of individuals. Further information can be found in our Privacy Policy.
Automated Decisions
We may also use personal information to make automated decisions (involving an element of profiling) as necessary for entering into the policy or otherwise authorised by law. For example we may make automated decisions, using an automated system, to decide if we can provide insurance (without going through a manual underwriting process) and if so at what premium. In particular, our automated underwriting system processes the personal and medical information provided as part of this application process (including age, smoking status, answers to our health and lifestyle questions, including family medical history), along with the amount of cover requested. We do this to calculate how much that cover will cost. Without this information we’re unable to provide a price that is relevant to your individual circumstances and needs. We regularly check the way our underwriting system works to ensure we’re being fair to our customers. For further information please see our Privacy Policy.
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. medical practitioners, lawyers, private investigators) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents and other third parties relevant to you and/or the policy, including doctors and other relevant medical practitioners, legal advisers and other pension providers.
- If we are required to do so to comply with a relevant legal or regulatory obligation; with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and Department of Social Protection.
- With other insurers and financial services companies, public bodies, (either directly or using shared databases) and industry bodies such as Insurance Ireland.
- With reinsurers who provide reinsurance services to Aviva and for each other. Reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations. They will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the later of the date when the customer relationship ceases or a claim in payment ceases.
Where you complete an application for but do not subsequently proceed with a policy of life insurance or cover is declined, underwriting details may be kept for a period of up to 6 years to facilitate a subsequent application or as a check against non-disclosure.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- object to our use of personal information based on legitimate interests or public interests;
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you; and
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Group Pensions
Group Pension Plan
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and pension products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to the employees, as members of the Group Pension Plan whose information is relevant to the insurance under the policy and the administration of the Group Pension Plan. This Data Protection Notice also applies (as regards the more limited information that we may hold e.g. contact details) to:
- signatories to the application for the policy
- directors of corporate trustee/employer of the Group Pension Plan
- individual trustees
- the employer if a sole trader or partnership.
The terms “you” and “your” are used accordingly in this Data Protection Notice.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us” or “our”), the insurer of the policy (issued to the trustees of the Group Pension Plan as Policy Owners). Additional data controllers involved in the policy and the Group Pension Plan include:
- trustees of the Group Pension Plan
- employer of the Group Pension Plan
- intermediary/financial broker (who is responsible for the sale and suitability of the product).
2. Type of Information/Where Collected
We collect personal information (such as name, age/DOB, salary, PPSN, contribution amounts, employment history, pensions history) from you and any relevant third parties (including that authorised by the Declarations) under and in relation to the application for the policy and the administration of the policy and the Group Pension Plan, to include processing benefits and complaints.
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 the application or a claim for benefit. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. (if benefits payable to them) spouse, dependants of the member of the Group Pension Plan.
| 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. We will facilitate trustees meeting this requirement for members of the Group Pension Plan by including a copy of the Data Protection Notice in the introductory member pack we issue to the financial broker for the policy. 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:
- already held about you within the Aviva Group (identified in Privacy Policy), including details from previous, policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from publicly available information including social media websites and online content, newspaper articles, tv, radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck), and (only for purposes of verifying your identity) electoral register;
- from other insurance companies, trustees of other pension schemes, previous employers and other pension providers.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider the application for the policy and the related administrative and regulatory requirements e.g. Revenue approval of the Group Pension Plan. |
| For the performance of a contract i.e. the insurance policy and administration of the Group Pension Plan | To administer the policy for the Policy Owners (the trustees of the Group Pension Plan) in accordance with the policy conditions (a copy of which are available on request from us or intermediary/financial broker), including: process benefit payments and the prevention and detection of fraud in respect of the policy support the administration of the Group Pension Plan e.g. arrange Revenue approval of the Group Pension Plan; address Pension Act requirements e.g. disclosure other statutory requirements e.g. pensions adjustment orders. |
| For compliance with a legal obligation | Compliance with relevant legal and regulatory obligations to include those (e.g. annual benefit statements, annual reports) if we act as Registered Administrator of the Group Pension Plan. |
| Legitimate Interests (of Aviva and/or Policy Owners and/or members of the Group Pension – Corporate Plan) | We may process personal information of people other than the Policy Owners, in order to:
consider the application for the policy and related administrative and regulatory requirements administer the policy and support the administration of the Group Pension Plan. This processing will also be in the legitimate interests of the Policy Owners in the conduct of their business and/or members of the Group Pension Plan in having access to and the benefit of the Group Pension Plan. |
| To protect your vital interests: | This will only arise in exceptional circumstances where we may use and/or disclose information to protect the members of the Group Pension Plan e.g. liaise with the Pensions Authority and/or Revenue Commissioners if trustee/employer in liquidation. |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as business in: managing our legal affairs including exercising our legal rights and defending claims; 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 theft and fraud. |
| Legitimate Interests (of Aviva) | Our legitimate interests to better understand our customers and improve service enhancement and business performance, this includes: customer analytics; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services; 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: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents and other third parties relevant to you and/or the policy, including your employer, previous employers, other insurance companies, trustees, administrators and other pension providers.
- If appropriate with regard to relevant legal/tax regulatory obligations and Revenue approval of the Group Pension Plan: with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Pensions Authority, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and Department of Employment Affairs and Social Protection.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and support the administration of the Group Pension Plan and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the later of the date when the customer relationship ceases.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information
- correct any mistakes on our records
- erase or restrict records where they are no longer required
- object to our use of personal information based on legitimate interests or public interests
- asking not to be subject to solely automated decision making if the decision produces legal or other significant effects on you
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Group AVC
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and pension products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to the employees, as members of the Group Pension Plan whose information is relevant to the insurance under the policy and the administration of the Group Pension Plan. This Data Protection Notice also applies (as regards the more limited information that we may hold e.g. contact details) to:
- signatories to the application for the policy
- directors of corporate trustee/employer of the Group Pension Plan
- individual trustees
- the employer if a sole trader or partnership.
The terms “you” and “your” are used accordingly in this Data Protection Notice.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us” or “our”), the insurer of the policy (issued to the trustees of the Group Pension Plan as Policy Owners). Additional data controllers involved in the policy and the Group Pension Plan include:
- trustees of the Group Pension Plan
- employer of the Group Pension Plan
- intermediary/financial broker (who is responsible for the sale and suitability of the product).
2. Type of Information/Where Collected
We collect personal information (such as name, age/DOB, salary, PPSN, contribution amounts, employment history, pensions history) from you and any relevant third parties (including that authorised by the Declarations) under and in relation to the application for the policy and the administration of the policy and the Group Pension Plan, to include processing benefits and complaints.
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 the application or a claim for benefit. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. (if benefits payable to them) spouse, dependants of the member of the Group Pension Plan.
| 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. We will facilitate trustees meeting this requirement for members of the Group Pension Plan by including a copy of the Data Protection Notice in the introductory member pack we issue to the financial broker for the policy. 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:
- already held about you within the Aviva Group (identified in Privacy Policy), including details from previous, policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from publicly available information including social media websites and online content, newspaper articles, tv, radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck), and (only for purposes of verifying your identity) electoral register;
- from other insurance companies, trustees of other pension schemes, previous employers and other pension providers.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider the application for the policy and the related administrative and regulatory requirements e.g. Revenue approval of the Group Pension Plan. |
| For the performance of a contract i.e. the insurance policy and administration of the Group Pension Plan | To administer the policy for the Policy Owners (the trustees of the Group Pension Plan) in accordance with the policy conditions (a copy of which are available on request from us or intermediary/financial broker), including: process benefit payments and the prevention and detection of fraud in respect of the policy support the administration of the Group Pension Plan e.g. arrange Revenue approval of the Group Pension Plan; address Pension Act requirements e.g. disclosure other statutory requirements e.g. pensions adjustment orders. |
| For compliance with a legal obligation | Compliance with relevant legal and regulatory obligations to include those (e.g. annual benefit statements, annual reports) if we act as Registered Administrator of the Group Pension Plan. |
| Legitimate Interests (of Aviva and/or Policy Owners and/or members of the Group Pension – Corporate Plan) | We may process personal information of people other than the Policy Owners, in order to: consider the application for the policy and related administrative and regulatory requirements administer the policy and support the administration of the Group Pension Plan. This processing will also be in the legitimate interests of the Policy Owners in the conduct of their business and/or members of the Group Pension Plan in having access to and the benefit of the Group Pension Plan. |
| To protect your vital interests: | This will only arise in exceptional circumstances where we may use and/or disclose information to protect the members of the Group Pension Plan e.g. liaise with the Pensions Authority and/or Revenue Commissioners if trustee/employer in liquidation. |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as business in: managing our legal affairs including exercising our legal rights and defending claims; 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 theft and fraud. |
| Legitimate Interests (of Aviva) | Our legitimate interests to better understand our customers and improve service enhancement and business performance, this includes: customer analytics; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services; 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: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents and other third parties relevant to you and/or the policy, including your employer, previous employers, other insurance companies, trustees, administrators and other pension providers.
- If appropriate with regard to relevant legal/tax regulatory obligations and Revenue approval of the Group Pension Plan: with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Pensions Authority, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and Department of Employment Affairs and Social Protection.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and support the administration of the Group Pension Plan and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the later of the date when the customer relationship ceases.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information
- correct any mistakes on our records
- erase or restrict records where they are no longer required
- object to our use of personal information based on legitimate interests or public interests
- asking not to be subject to solely automated decision making if the decision produces legal or other significant effects on you
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Group Buy Out Bond
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and pension products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to Applicants (i.e. the Trustees of the Existing Scheme as identified in this Application) and the Policy Owner (i.e. the member of the Existing Scheme and ultimate buy out bond owner). The terms “you” and “your” are used accordingly in this Data Protection Notice.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us”, “our”) as the provider of the product. Your intermediary/financial broker (who is responsible for the sale and suitability of the product) will be an additional data controller for obtaining and maintaining the product. The Trustees of the Existing Scheme (as identified in this Application) will also be an additional data controller for the process of obtaining the product.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing policy options, benefit payments and complaints.
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 any claim you make. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. limited personal information on your employer (or past employer), nominated representatives, personal representatives and attorneys (under powers of attorney).
| If you are providing personal information about another person, unless the provision of such information proves impossible, 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:
- already held about you within the Aviva Group (identified in our Privacy Policy), including details from previous, policies of insurance and claims;
- from your intermediary, financial broker or other nominated representatives or agents;
- from publicly available information including social media websites and online content, newspaper articles, tv, radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register; and
- from other third parties relevant to you and/or the policy, including your employer (or past employer), other insurance companies, trustees, administrators and providers of relevant pension arrangements.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether to accept this application and consider the related administrative and regulatory requirements e.g. eligibility for a buy out bond. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the Policy Owner in accordance with the policy conditions (a copy of which are available on request from us or the intermediary/financial broker), including to evaluate, validate and/or process transfers, benefit payments, policy options and complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations. |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva, the Applicants and/or the Policy Owner) | We may process personal information of the Policy Owner at the request of the Applicant only (e.g. where a Trustee is requesting a policy to be set up without consent). We may also process personal information of people other than you to administer the policy including processing transfers, policy options, benefit payments and complaints for the benefit of the Policy Owner. |
| 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; 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 better understand our customers and improve service enhancement and business performance, this includes customer analytics; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services ; 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: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. lawyers) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents, nominated representatives and other third parties relevant to you and/or the policy, including your employer (or past employer), other insurance companies, trustees, administrators and providers of relevant pension arrangements.
- If we are required to do so to comply with a relevant legal or regulatory obligation; with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau and Data Protection Commission and National Treasury Management Agency.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the date when the customer relationship ceases.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- object to our use of personal information based on legitimate interests or public interests;
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you; and
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Group Protection
Group Life Insurance
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and pension products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to the lives to be insured whose information is relevant to the insurance under the policy and the administration of the Scheme of which the lives insured are members. This Data Protection Notice also applies (as regards the more limited information that will hold in respect of them (e.g. as regards their contact details) to:
- signatories to the application for the policy
- the directors of corporate trustee/employer of the Scheme
- individual trustees of the Scheme
- the employer if a sole trader or a partnership.
The terms “you” and “your” are used accordingly in this Data Protection Notice.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we” “us” “our”) as the insurer of the of the policy (issued to the trustees of the Scheme as Policy Owners). Additional data controllers involved in policy and the Scheme include:
- trustees of the Scheme
- employer of the Scheme
- intermediary/financial broker (who is responsible for the sale and suitability of the product).
Risk assessment for Group Protection will be carried out on anonymised basis (i.e. without identifying personal information of the lives insured) where appropriate. We mainly process personal information of the lives insured:
- if individual risk assessment/underwriting applies (e.g. because cover amount exceeds our free cover limit)
- where a benefit is claimed under the policy
- administering benefits.
2. Type of Information/Where Collected
We collect personal information (including name, age/DOB, salary, PPSN, employment history, pensions history) from you and any relevant third parties (including that authorised by the Declarations) under and in relation to the application for the policy and the administration of the policy and the Scheme, to include processing claims and complaints.
We may need to ask for health data relevant to the policy. We recognise that information about health is particularly sensitive information. We will only collect and use such information where we need to and where it is proportionate for the purposes of the policy of insurance.
Health data includes (with the exception of the results of genetic tests) lives to be insured health data to include, existing or previous health conditions, medical history and lifestyle (e.g. smoking habits/history) and family health history. If you are asked to provide health data, please do not send us the results of any genetic tests carried out on you or any other relevant person.
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 the application, cover for a life or lives to be insured or claim for benefit. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. where individual underwriting applies family health history of the lives insured, (if benefits payable to them) spouse/dependants of members the Scheme.
| 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:
- already held about you within the Aviva Group (identified in Privacy Policy) , including details from previous, policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from parties relevant to claim process (e.g. claimant, private investigators engaged by us, witnesses, solicitors and independent experts);
- from publicly available information including social media websites and online content, newspaper articles, tv, radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck), and (only for purposes of verifying your identity) electoral register;
- from other insurance companies, trustees of other pension schemes, previous employers, other pension providers.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
(a) Personal Information (other than health data)
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy |
To consider whether (and if so on what terms) to accept the application for the policy to include:
assessing the lives to be insured for underwriting/risk purposes (e.g. where outside free cover limits or other group protection parameters, determining what premiums will apply, protection against non-disclosure of material facts and preventing or detecting fraud having regard to the related administrative and regulatory requirements e.g. Revenue approval of the Scheme. |
| For the performance of a contract i.e. the insurance policy and administration of Scheme | To administer the policy for the Policy Owners in accordance with the policy conditions (a copy of which are available on request from us or intermediary/financial broker), including to: evaluate, validate and process any claims and complaints and the prevention and detection of fraud in respect of the policy support the administration of the Scheme e.g. arrange Revenue approval of the Scheme address Pension Act requirements e.g. disclosure other statutory requirements e.g. pension adjustment orders. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations |
| Legitimate Interests (of Aviva and/or the Policy Owners and/or the lives insured/members) | We may process personal information of people other than the Policy Owners, in order to: consider the application for the policy and related administrative and regulatory requirements administer the policy and support the administration of the Scheme. This processing will also be in the legitimate interests of the Policy Owners in the conduct of their business and/or the lives insured/members of the Scheme in having access to and the benefit of the Scheme. |
| To protect your vital interests: | This will only arise in exceptional circumstances where we may use and/or disclose information to protect the members of the Scheme e.g. liaise with the Pensions Authority and/or Revenue Commissioners if trustee/employer in liquidation |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as a business in assessing our reinsurance requirements and managing arrangements we have with reinsurers (these arrangements are necessary for risk transfer by insurers); managing our legal affairs including exercising our legal rights and defending claims; 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 theft and fraud. We may use your personal information to make searches of our records, if you give us false personal information or fail to disclose personal information during the application or claims process and we suspect fraud we will record this. |
| Legitimate Interests (of Aviva) | Our legitimate interests to better understand our customers and improve service enhancement and business performance, this includes customer analytics; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services; and in the event of any portfolio transfer, merger, acquisition, disposal or other suchtransaction 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: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
(b) Health Data
Health data is used for the purposes of set-up and underwriting of policy of insurance, administering policy (e.g. processing claims, handling complaints), reinsurance or fraud investigation in relation to the policy.
The legal basis on which we process health data in respect of the lives to be insured is that:
- Irish Data Protection law allows us where necessary and proportionate to use heath data for the purposes of a policy of insurance; and/or
- processing is necessary for the establishment, exercise or defence of legal claims.
Where we process health data for the purpose of a policy of insurance we will take suitable and specific measures to safeguard the fundamental rights and freedoms of individuals. Further information can be found in our Privacy Policy.
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. medical practitioners, lawyers, private investigators) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker.
- Your agents and other third parties relevant to you and/or the policy, including doctors and other relevant medical practitioners, employer, previous employers, other insurance companies, trustees, administrators and other pension providers.
- If appropriate with regard to relevant legal/tax regulatory obligations and Revenue approval of the Scheme: with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Pensions Authority, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and Department of Social Protection.
- With other insurers and financial services companies, public bodies, (either directly or using shared databases) and industry bodies such as Insurance Ireland.
- With reinsurers who provide reinsurance services to Aviva and for each other. Reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations. They will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and support the administration of the Scheme and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the later of the date when the customer relationship ceases or a claim in payment ceases.
Where individual underwriting applies but cover not subsequently taken out or cover is declined, underwriting details may be kept for a period of up to 3 years to facilitate a subsequent application or as a check against non-disclosure.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information
- correct any mistakes on our records
- erase or restrict records where they are no longer required
- object to our use of personal information based on legitimate interests or public interests
- asking not to be subject to solely automated decision making if the decision produces legal or other significant effects on you
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Group Income Protection
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and pension products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to the lives to be insured whose information is relevant to the insurance under the policy. This Data Protection Notice also applies to the directors/signatories to this application for corporate Policy Owner or to individual Policy Owner as regards the more limited information that we will hold in respect of them (e.g. their contact details). The terms “you” and “your” are used accordingly in this Data Protection Notice.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us”, “our”) as the insurer of the policy issued to the employer (of the lives insured) as Policy Owner. Additional data controllers involved in the process for obtaining and maintaining insurance cover include the Policy Owner (who is employer of the lives insured), intermediary/financial broker (who is responsible for the sale and suitability of the product) and applicable reinsurers.
Risk assessment for Group Protection will be carried out on anonymised basis (i.e. without identifying personal information of the lives insured) where appropriate. We mainly process personal information of the lives insured:
- if individual risk assessment/underwriting applies (e.g. because cover amount exceeds our free cover limit)
- where a benefit is claimed under the policy
- administering benefits.
2. Type of Information/Where Collected
We collect personal information (including name, age/DOB, salary, PPSN, pension contributions, employment status/history) from you and any relevant third parties (including that authorised by the Declarations) under and in relation to the application for the policy and the administration of the policy, to include processing claims and complaints.
We may need to ask for health data relevant to the policy. We recognise that information about health is particularly sensitive information. We will only collect and use such information where we need to and where it is proportionate for the purposes of the policy of insurance.
We may also use personal information about people other than you e.g. where individual underwriting applies family health history of the lives insured.(with the exception of the results of genetic tests) lives to be insured health data to include, existing or previous health conditions, medical history and lifestyle (e.g. smoking habits/history) and family health history. If you are asked to provide health data, please do not send us the results of any genetic tests carried out on you or any other relevant person.
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 the application, cover for a life or lives to be insured or claim for benefit. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. where individual underwriting applies family health history of the lives insured.
| 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:
- already held about you within the Aviva Group (identified in Privacy Policy), including details from previous, policies of insurance and claims;
- from the intermediary, financial broker or other nominated representative;
- from parties relevant to claim process (e.g. claimant, private investigators engaged by us, witnesses, solicitors and independent experts);
- from publicly available information including social media websites and online content, newspaper articles, tv, radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck), and (only for purposes of verifying your identity) electoral register;
- from other insurance companies, previous employers.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
(a) Personal Information (other than health data)
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether (and if so on what terms) to accept the application for the policy to include: assessing the lives to be insured for underwriting/risk purposes (e.g. where outside free cover limits or other group protection parameters), determining what premiums will apply, protection against non-disclosure of material facts and preventing or detecting fraud protection against non-disclosure of material facts and preventing or detecting fraud |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the Policy Owners in accordance with the policy conditions (a copy of which are available on request from us or intermediary/financial broker), including to evaluate, validate and process any claims and complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations |
| Legitimate Interests (of Aviva and/or the Policy Owners and/or the lives insured) | We may process personal information of people other than the Policy Owners, in order to consider the application for the policy and administer the policy to include processing claims and complaints for the benefit of the Policy Owners and/or the lives insured. |
| To protect your vital interests: |
This will only arise in exceptional circumstances where we may use and/or disclose information to protect the lives insured e.g. employer in liquidation |
| Legitimate Interests (of Aviva) | To support the legitimate interest that we have as a business in assessing our reinsurance requirements and managing arrangements we have with reinsurers (these arrangements are necessary for risk transfer by insurers); managing our legal affairs including exercising our legal rights and defending claims; 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 theft and fraud. We may use your personal information to make searches of our records, if you give us false personal information or fail to disclose personal information during the application or claims process and we suspect fraud we will record this. |
| Legitimate Interests (of Aviva) | Our legitimate interests to better understand our customers and improve service enhancement and business performance, this includes customer analytics; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services; 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: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
(b) Health Data
Health data is used for the purposes of set-up and underwriting of the policy of insurance, administering the policy (e.g. processing claims, handling complaints), reinsurance or fraud investigation in relation to the policy.
The legal basis on which we process health data in respect of the lives to be insured is that:
- Irish Data Protection law allows us where necessary and proportionate to use heath data for the purposes of a policy of insurance; and/or
- processing is necessary for the establishment, exercise or defence of legal claims.
Where we process health data for the purpose of a policy of insurance we will take suitable and specific measures to safeguard the fundamental rights and freedoms of individuals. Further information can be found in our Privacy Policy.
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. medical practitioners, lawyers, private investigators) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker.
- Your agents and other third parties relevant to you and/or the policy, including doctors and other relevant medical practitioners, employer, previous employers, other insurance companies.
- If we are required to do so to comply with a relevant legal or regulatory obligation: with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and Department of Employment Affairs and Social Protection.
- With other insurers and financial services companies, public bodies, (either directly or using shared databases) and industry bodies such as Insurance Ireland.
- With reinsurers who provide reinsurance services to Aviva and for each other. Reinsurers will use your data to decide whether to provide reinsurance cover, assess and deal with reinsurance claims and to meet legal obligations. They will keep your data for the period necessary for these purposes and may need to disclose it to other companies within their group, their agents and third party service providers, law enforcement and regulatory bodies.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the later of the date when the customer relationship ceases or a claim in payment ceases.
Where individual underwriting applies but cover not subsequently taken out or cover is declined, underwriting details may be kept for a period of up to 3 years to facilitate a subsequent application or as a check against non-disclosure.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information
- correct any mistakes on our records
- erase or restrict records where they are no longer required
- object to our use of personal information based on legitimate interests or public interests
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
PRSAs
Individual PRSA
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and pension products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to the Applicant/Policy Owner (referred to in this Data Protection Notice as “you” and “your”).
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us”, “our”) as the provider of the product. Your intermediary/financial broker (who is responsible for the sale and suitability of the product) will be an additional data controller in obtaining and maintaining the product.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing benefits and complaints.
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 any claim you make. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. limited personal information on administrators/managers of a relevant pension arrangement, your nominated representatives, personal representatives and your attorneys (under powers of attorney).
| 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:
- already held about you within the Aviva Group (identified in our Privacy Policy), including details from previous policies of insurance and claims;
- from your intermediary, financial broker or other nominated representative;
- from publicly available information including social media websites and online content, newspaper articles, tv radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register; and
- from other insurance companies and other pension providers.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process your personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether to accept this application and consider the related administrative and regulatory requirements e.g. eligibility for a personal pension.
|
| For the performance of a contract i.e. the insurance policy | To administer the policy for you in accordance with the policy conditions (a copy of which are available on request from us or your intermediary/financial broker), including to evaluate, validate and/or process transfers, benefit payments, policy options and complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations. |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the Policy Owner) | We may process personal information of people other than the Policy Owner to administer the policy, including processing transfers, benefit payments, policy options and complaints for the benefit of the Policy Owner. |
| 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; 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 better understand our customers and improve service enhancement and business performance, this includes customer analytics; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services (including AvivaOnline); 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. |
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. lawyers) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents, nominated representatives and other third parties relevant to you and/or the policy, including your legal advisers, other insurance companies and relevant pension providers.
- If we are required to do so to comply with a relevant legal or regulatory obligation: with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and National Treasury Management Agency.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the date when the customer relationship ceases.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- object to our use of personal information based on legitimate interests or public interests;
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you; and
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Employer PRSA
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and pension products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to the Applicant/Policy Owner. This Data Protection Notice may also apply to others (e.g. an employer who completes our employer registration process) in relation to the personal information that we will hold in respect of them (e.g. contact details, bank details). The terms “you” and “your” are used accordingly in this Data Protection Notice.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us”, “our”) as the provider of the product. Your intermediary/financial broker (who is responsible for the sale and suitability of the product) will be an additional data controller in obtaining and maintaining the product.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing policy options, benefit payments and complaints.
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 any claim made under the policy.
We may also use personal information about people other than you e.g. limited personal information of trustees, administrators or managers of a relevant pension arrangement, your nominated representatives, personal representatives and attorneys (under powers of attorney).
| 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:
- already held about you within the Aviva Group (identified in our Privacy Policy), including details from previous, policies of insurance and claims;
- from the intermediary, financial broker or other nominated representative;
- from publicly available information including social media websites and online content, newspaper articles, tv radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register; and
- from an employer, other relevant insurance companies and pension providers.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether to accept this application and consider the related administrative and regulatory requirements. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the Policy Owner in accordance with the policy conditions (a copy of which are available on request from us or your intermediary/financial broker), including to evaluate, validate and/or process transfers, benefit payments, policy options and complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation |
Compliance by us with all relevant legal and regulatory obligations. |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the Policy Owner) | We may process personal information of people other than you to administer the policy including processing transfers, policy options, benefit payments and complaints for the benefit of the Policy Owner. |
| 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; 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 better understand our customers and improve service enhancement and business performance, this includes customer analytics; market research; processing management information; reporting (including Aviva Group reporting) for compliance, audit, statistical or research purposes; staff training; providing online services (including AvivaOnline); 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: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. lawyers) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents, nominated representatives and other third parties relevant to you and/or the policy, including your employer (eg to facilitate salary deduction), your legal advisers, other insurance companies and trustees, administrators or managers of a relevant pension arrangement.
- If we are required to do so to comply with a relevant legal or regulatory obligation; with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Pensions Authority, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and National Treasury Management Agency.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the date when the customer relationship ceases.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- object to our use of personal information based on legitimate interests or public interests;
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you; and
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Group PRSA
Data Protection Notice
1. Introduction
We collect and use personal information about individuals so that we can provide insurance and pension products requested by our customers. 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/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 W2P5 or call us on (01) 8987000.
This Data Protection Notice applies mainly to the Applicant/Policy Owner. This Data Protection Notice may also apply to others (e.g. an employer who completes our employer registration process) in relation to the personal information that we will hold in respect of them (e.g. contact details, bank details). The terms “you” and “your” are used accordingly in this Data Protection Notice.
The data controller responsible for processing this personal information is Aviva Life & Pensions Ireland DAC (“we”, “us”, “our”) as the provider of the product. Your intermediary/financial broker (who is responsible for the sale and suitability of the product) will be an additional data controller in obtaining and maintaining the product.
2. Type of Information/Where Collected
We collect personal information from you and any relevant third parties (including that authorised by the Declarations) under and in relation to this Application and the administration of the policy, to include processing policy options, benefit payments and complaints.
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 any claim made under the policy. We will let you know what information is required to proceed with your application or any claim you make.
We may also use personal information about people other than you e.g. limited personal information of trustees, administrators or managers of a relevant pension arrangement, your nominated representatives, personal representatives and attorneys (under powers of attorney).
| 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:
- already held about you within the Aviva Group (identified in our Privacy Policy), including details from previous, policies of insurance and claims;
- from the intermediary, financial broker or other nominated representative;
- from publicly available information including social media websites and online content, newspaper articles, tv, radio and other media content, court judgements, public registers and specialist databases (for example Companies Registration Office, Vision-net, Oracle, Dow Jones, SoloCheck) and (only for purposes of verifying your identity) electoral register; and
- from an employer, other relevant insurance companies and pension providers.
3. Legal Basis and Purposes for Use
The legal basis we rely on to process personal information and the purposes for which we collect and use personal information are summarised below. Further information is set out in our Privacy Policy.
| Legal Basis for Use | Purposes for Use |
| In order to take steps prior to entering into a contract i.e. the insurance policy | To consider whether to accept this application and consider the related administrative and regulatory requirements. |
| For the performance of a contract i.e. the insurance policy | To administer the policy for the Policy Owner in accordance with the policy conditions (a copy of which are available on request from us or your intermediary/financial broker), including to evaluate, validate and/or process transfers, benefit payments, policy options and complaints and the prevention and detection of fraud in respect of the policy. |
| For compliance with a legal obligation | Compliance by us with all relevant legal and regulatory obligations. |
| To protect your vital interests | This will only arise in exceptional circumstances where we may use and/or disclose information to protect you, for example, Ward of Court applications or equivalent processes. |
| Legitimate Interests (of Aviva and/or the Policy Owner) | We may process personal information of people other than you to administer the policy including processing transfers, policy options, benefit payments and complaints for the benefit of the Policy Owner. |
| 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; and |
| 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 better understand our customers and improve service enhancement and business performance, this includes customer analytics; 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: we will have an opportunity to demonstrate that there are compelling legitimate grounds which override your rights and freedoms or that processing is necessary for the establishment, exercise or defence of legal claims; a successful objection may have consequences for our continued administration of the policy (e.g. prevent us assessing future claims and/or the policy may be cancelled) and we can discuss these if you want to object. |
|---|
4. Who we share your information with
Where relevant, we may share personal information with:
- Other Aviva Group companies, agents, professional advisers acting for us (e.g. lawyers) and third party service providers.
- The intermediary/financial broker and at its request, third party service providers who provide services to the intermediary/financial broker (e.g. software providers who give brokers an overview of customer information across different insurance providers).
- Your agents, nominated representatives and other third parties relevant to you and/or the policy, including your employer (eg to facilitate salary deduction), your legal advisers, other insurance companies and trustees, administrators or managers of a relevant pension arrangement.
- If we are required to do so to comply with a relevant legal or regulatory obligation; with regulatory bodies, law enforcement bodies, government departments including Central Bank of Ireland, Financial Services and Pensions Ombudsman, Pensions Authority, Revenue Commissioners/Inspector of Taxes, Gardaí, Criminal Assets Bureau, Data Protection Commission and National Treasury Management Agency.
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.
5. How long we keep your personal information for
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 personal information for the period necessary to administer the policy and as long as is required/permitted by law and/or in respect of any potential dispute in relation to the policy. Currently this would commonly be 7 years from the date when the customer relationship ceases.
6. Your rights
You have various rights in relation to your personal information, including the right to:
- request access to your personal information;
- correct any mistakes on our records;
- erase or restrict records where they are no longer required;
- object to our use of personal information based on legitimate interests or public interests;
- ask not to be subject to solely automated decision making if the decision produces legal or other significant effects on you; and
- move (in a structured, commonly used and machine-readable format) certain data to other providers (data portability).
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.
7. Contacting us
If you have any questions about how we use 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 W2P5 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.
Aviva Direct Ireland Limited is regulated by the Central Bank of Ireland. A private company limited by shares. Registered in Ireland No 374895. Registered Office: Cherrywood Business Park, Dublin, Ireland, D18 W2P5.
Aviva Insurance Ireland Designated Activity Company, trading as Aviva, is regulated by the Central Bank of Ireland. A private company limited by shares. Registered in Ireland No. 605769. Registered Office: Cherrywood Business Park, Dublin, Ireland, D18 W2P5.
Aviva Life & Pensions Ireland Designated Activity Company, a private company limited by shares. Registered in Ireland No. 165970. Registered office at Building 12, Cherrywood Business Park, Loughlinstown, Co. Dublin, D18 W2P5. Aviva Life & Pensions Ireland Designated Activity Company, trading as Aviva Life & Pensions Ireland and Friends First, is regulated by the Central Bank of Ireland. Tel (01) 898 7950.