Your rights, your data and how we use it
Island Financial Solutions Limited (IFS) are committed to protecting and respecting your privacy. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Act 2002 (Act of Tynwald) the data controller is IFS, which is located at the address below.
This policy was updated in order to meet the standards set out in the European Union's (EU) General Data Protection Regulation (GDPR) and this policy shall be governed by and construed in accordance with Manx law. The information on this website is primarily intended for residents of the Isle of Man but can be extended to citizens of EU member states if applicable.
IFS may need to amend or update this policy; so please check this page periodically. However, if there is any important changes, such as changes relating to personal data processing, we will inform you directly.
How to contact us
Data Protection Officer
Island Financial Solutions Limited
Isle of Man
Tel 01624 614618
Fax 01624 614818
What data is collected and used by Island Financial Solutions Limited?
IFS operate in the financial services sector, where data handling and confidentiality are key issues. Our business primarily involves handling personal data, which is confidential to our clients.
Under European Law, it is required that we have your consent before we collect or use any personal information about our potential clients (that are EU citizens) or pass it on to any third parties. In order to obtain the client?s consent, we require any potential clients to complete and sign a Data Consent Declaration.
This website is used by IFS to inform you of the services we offer, and that and your personal data will be treated in strict confidence and will only be disclosed by us in limited circumstances, for example to product providers in the course of preparing or implementing our advice, or to meet legal or regulatory requirements, including fraud prevention measures. The information required to complete any enquiry or proposal form shall be treated with the utmost confidentiality by IFS.
In order to do this, IFS must obtain certain information about you regarding your personal and financial circumstances. The information that you provide to us will then be passed by us to potential providers and researchers who will use the information in order to respond with the terms that they have found or that they are willing to offer.
IFS will only collect the minimum details from you that are required to fulfil its? obligations to implement your instructions and, where appropriate, provide suitable advice and to ensure that our recommendations fit with your current circumstances.
Therefore, you must agree to the following:
- Any information that we hold on our clients can be held digitally or on hard copy paper files and seen by employees and agents in order to provide or hope to provide products and services to you, the client.
- Any information that you provide to IFS, including sensitive personal data such as health and medical records, may be disclosed to third parties for the purposes of finding the most suitable product available when processing your application.
- We may disclose information about you to insurance companies and other product providers in order to process your application.
- We will disclose your basic personal information to eSpear/Regulatory DataCorp (RDC) in order to conduct a background check (Anti-Money Laundering and client due-diligence screening), who are incorporated in the United States of America, with servers located in Europe.
- Although we will try to obtain the most competitive product for you we will not send your personal details outside the European Union, United Kingdom or the Isle of Man.
Information about you that IFS may collect and use includes the following:
- Information about who you are, e.g. your name, date of birth and contact details.
- Information connected to your products and/or services that have been facilitated through us, e.g. your bank account details
- Information about your contact with us, e.g. meetings, phone calls, emails and letters
- Information that is collected automatically, e.g. via cookies when visiting www.ifs.im
- Information classified as ?sensitive? personal information, e.g. relating to your health, marital or civil partnership status. This information will only be collected and used where it is needed to provide the product or service you have requested or in order to comply with legal or regulatory obligations.
- Information you may provide us about other people, e.g. joint applicants or beneficiaries for products and/or services.
- Information on children, e.g. where a child is named as a beneficiary on a policy taken out by a parent or guardian on their behalf. In these cases, IFS will only collect and use only the information required in order to identify the child, e.g. their name, age, gender etc.
Your details are collected when you complete quote request forms, application forms, requests for guidance or when you send us an e-mail.
Please note that the information we ask for is necessary. Without it we may not be able to advise you fully due to the operation of the rules of the Isle of Man Financial Services Authority (IOMFSA). We use this for our regulatory obligation in fact finding, and to provide recommendations as detailed above.
A cookie is a small file which asks permission to be placed on your computer?s hard drive when you visit our website.
Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.
Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
Like many sites, we use "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.
IFS may use your contact details to let you know about other products and services which may be of interest to you by telephone, email or letter, unless we are specifically advised not to do so. Information may be used to conduct statistical analysis and surveys, and should this happen you would not be identified personally. We do not sell customer information to third parties. You can opt in or out via the Data Consent Declaration form, which is presented to you at the first meeting.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect from you.
Where we collect your data
IFS may collect your personal information directly from you, and/or from a variety of sources, which include:
- An application form for a product/service
- Telephone conversations with IFS employees
- Emails and letters delivered to IFS
- Meetings with one of our financial advisers
- Our online services, e.g. websites, social media
What we collect and use your data for
We take your privacy very seriously and we will only ever collect personal data where it is fair, necessary and lawful to do so. IFS will only collect and use your information in the following circumstances:
- You have given us explicit positive consent for IFS to send you information relating to the products/services you currently have trough us and in addition to marketing materials.
- Where is it necessary for us to meet our legal or regulatory obligations, e.g. to send you investment portfolio reports, or to tell you about changes to our Terms of Business or for the detection and in the prevention of fraud.
If you do not wish us to collect and use your personal information in these ways, it may mean that IFS will be unable to facilitate and advise on products/services for you.
Who we may share your data with
IFS may share your personal data with third parties for the reasons outlined in the previous section: ?What we collect and use your data
These third parties include the following:
- Product providers
- Fraud prevention identity verification agencies ? eSpear
- Supporting Companies, e.g. Internet Service Provider
- Your employer if you have a group personal pension through them
- Back office software - Intelligent office, Dynamic Planner, Truth, Selectapension
- Our regulators and Supervisory Authority e.g. the Isle of Man Financial Services Authority (IOMFSA) and the Isle of Man Information Commissioner
- Law enforcement agencies for the prevention and detection of crime
We will never sell you details to a third party. Whenever we share your personal data, we will do so in line with our obligations to keep your information safe and secure.
Where your data is processed
Your data will be located and processed in the Isle of Man, United Kingdom and the European Economic Area (EEA) exclusively.
How we protect your information
IFS takes information and system security very seriously and we endeavour to comply with our legal and regulatory obligations at all times.
Any personal information that is collected, recorded or used in any way, whether physical or electronic media, will have appropriate safeguards in place that are in accordance with our data protection obligations.
You personal data is protected by controls and processes that are designed to reduce the risk exposure and any loss/damage due to: accident, negligence or deliberate actions.
IFS's employees also actively protect sensitive/confidential information during storage and transmission and will partake in annual refresher training on this subject.
IFS's security controls and procedures are in line with industry standards and best practice principles and we facilitate a controlled environment that effectively manages and mitigates risks relating to confidentiality, integrity and the availability of your personal information.
How long we keep your information for
IFS will keep your personal information only where it is necessary to provide you with our products or services while you remain as a client.
However, IFS may keep your data after this period in cases there it is required to meet our legal or regulatory obligations. The retention duration of your personal data will vary depending of the obligations that need to be met.
IFS will retain records of all transactions undertaken for clients for at least six years from the date of each transaction. Such records include policy details,86 contract notes and copies of entries held either in paper or in a computerised form.
Your individual rights
As an individual, you possess several rights in relation to how IFS collects and processes your personal data, which are the following:
Right to be informed
Right of access
You have the right of information access of your personal data. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR) to the above address.
Right to request that your personal data be rectified
If in the unlikely event that your personal data is inaccurate or incomplete, you can request that it be corrected.
Right to request erasure
You reserve the right to request that your personal data be deleted or removed if there is no compelling reason for Island Financial Solutions to be in possession of it.
Right to restrict processing
You can request that IFS stifle the processing of your personal data for certain reasons. Basically, this means that IFS is still permitted to keep your personal data, but only to ensure that we do not process it in the future due to the restriction reasons you have stipulated.
Right to data portability
You have the right to request for a copy of your personal data held by IFS for use for your own purposes and uses. In certain circumstances, you may move, copy or transfer the personal information we hold on you in a safe and secure way, e.g. if you were moving to another independent financial advisory firm.
Right to object
You can make an objection to IFS processing your personal data where:
- It's based on our legitimate interests.
- For direct marketing purposes.
- If we are using it for research and statistical analysis.
Third Party Links
Our website may contain links to other websites of interest, such as the Business News section and the Best Business Guide. However, once you have used these links to leave our website, you acknowledge and agree that we are not responsible for the content, availability or functionality of such external sites.
Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
We do not endorse the contents of any external sites and are not responsible or liable, directly or indirectly, for any loss however caused to you by your use of any external site linked though www.ifs.im.
We reserve the right to temporarily/permanently modify or withdraw the website or any section of it without notice to you.
We reserve the right at any time to refuse to process a transaction from our website for any reason. We will not be liable to you or any third party by reason of failing to process a transaction.
How to make a complaint
IFS will always strive to collect, use and safeguard your personal data in accordance with data protection laws.
However, if you are still unhappy, you can complain to our Supervisory Authority.
Their contact details are:
Sunday 24th February, 2019
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