1. Who is responsible for your data
WH Ireland Limited (“WH Ireland”) recognise the importance of respecting your information and maintaining confidentiality.
WH Ireland is acting as the data controller for the purposes of this agreement, pursuant to the terms of The Data Protection Act 2018 (being the UK’s implementation of the General Data Protection Regulation (EU2016/679) (“UK GDPR”). WH Ireland’s registered office is at 24 Martin Lane, London EC4R 0DR and its telephone number is 0207 220 1666. If you want to discuss how your information is processed you can contact the Data Protection Officer of WH Ireland who can be contacted on email@example.com or at the address and on the telephone number set out in this paragraph.
2. Types of personal data we collect
WH Ireland collects personal data from you at various points during our relationship with you, including when applying to become a Client, or using our website. We may collect and process the following categories of information about you (please note this list is not exhaustive):
|Category of Personal Information||Description|
|Personal identifiers||Title, name, surname, gender, date of birth.|
|Contact||Permanent residential address, correspondence address, home / mobile / work phone number and E-mail address.|
|Social demographic||Nationality, country of birth, city of birth, country of issue of identity card / passport, Politically Exposed Person (“PEP”) classification, tax residency, employment and earnings.|
|Documentary evidence||Details about you stored on documents in different formats, or copies of them. This may include documents such as passport, drivers licence, birth certificate or bank statements.|
|Social relationships||Marital status and nominated beneficiaries.|
|Financial data||Bank accounts, IBAN numbers and SWIFT / BIC codes.|
|National identifier||A number or code given to you by a government to identify who you are, such as a national insurance number, passport number or Tax Identification Number.|
|Behavioural||Investment risk profile, other investment arrangements (which may be intended to be transferred to our arrangement), intended retirement age, and nominated beneficiaries linked to death benefits.|
You may also provide further information (either on request or voluntarily) by email, post, in face-to-face meetings or by phone. Finally, your third parties appointed by you may also pass on information to us which you have provided to them and which relates to the administration of our services.
3. How we collect your personal data
We collect information from our Clients predominantly through our application form but also through any subsequent interactions with you. We use different methods to collect data from and about you, including through:
The above lists under each method are not exhaustive.
4. Why and how WH Ireland uses your personal data
WH Ireland uses your personal data for the following purposes:
5. How long WH Ireland retains your personal data
WH Ireland will keep your personal data during the period you are a Client, and in most instances up to six years once this relationship has ceased, for the following reasons:
WH Ireland may also keep your personal data for research or statistical purposes. In these circumstances, appropriate measures will be established to ensure your privacy is protected, and the personal data is only used for the purposes intended.
6. Sharing your personal data
WH Ireland might share your personal data with third parties, in limited circumstances. Predominantly that sharing is carried out in order to ensure that our services are provided and administered successfully and in compliance with our regulatory and professional obligations. Your personal data may be shared by WH Ireland as follows:
7. Sharing your personal data internationally
As set out above, WH Ireland will share your information within the WH Ireland group of companies and with third parties. As such, this may involve transferring your personal data internationally to receivers located outside the UK. WH Ireland will take steps to ensure that transfers of personal data to receivers located outside of the UK are legitimate and, are covered by either UK adequacy regulations (in respect of the EEA and all countries, territories and international organisations covered by European Commission adequacy decisions valid as at 31 December 2020), or who has adopted appropriate safeguards as listed in Article 46 of the UK GDPR. WH Ireland will only share your personal data outside of the UK where it has decided that the third country where your data will be shared provides an adequate level of protection. By using this website, you consent to any such transfer of information outside of your country.
8. Security of your personal data
WH Ireland is committed to protecting the security of your personal information. A variety of security technologies and procedures are used to protect your personal information from unauthorised access, use, or disclosure.
9. Cookies or other tracking technologies
10. Sharing your personal data internationally
In addition to our Data Protection and Privacy Notification Policy, your privacy is protected by law. WH Ireland are legally only allowed to collect and process personal data where there exists a proper reason to do so. The law says WH Ireland must have one or more of these reasons:
Below is a list of ways in which we may use your personal data, which of the reasons we rely on to do so, and what our legitimate interests are (this is not an exhaustive list):
|Why we use your information||Our reasons||Our legitimate interest|
|To manage our relationship with you; To develop new ways to meet our members’ needs and grow our business; To provide guidance about our products and services.||Your explicit consent; Fulfilling contractual obligations; Our legitimate interests; Our legal duty.||Keeping our records about you up to date; Seeking your consent when we need it to contact you; Being efficient about how we fulfil our legal and contractual duties.|
|To deliver our products and services; To make and manage customer payments; To collect and recover money owed to us.||Fulfilling contractual obligations; Our legitimate interest; Our legal duty.||To develop products and services and what we charge for them; Being efficient about how we fulfil our legal and contractual duties.|
|To detect, investigate, report and seek to prevent financial crime; To manage risk for us and our customers; To comply with laws and regulations applicable to us; To respond to complaints and seek to resolve them.||Fulfilling contractual obligations; Our legitimate interest; Our legal duty.||To develop and improve how we deal with financial crime, as well as carrying out our legal duties; Comply with regulations applicable to us; Being efficient about how we fulfil our legal and contractual duties.|
|To run our business in an efficient manner by managing our business capability, planning, governances, communications and audit.||Our legitimate interest; Our legal duty.||Comply with regulations applicable to us; Being efficient about how we fulfil our legal and contractual duties.|
WH Ireland does not intentionally collect personal data that could reveal your racial or ethnic origin, physical or mental health, religious beliefs or alleged commission or conviction of criminal offences. Such information is considered “sensitive personal data”.
WH Ireland will only collect this information where one of the above reasons are satisfied. We cannot prevent you or a third party appointed by you from disclosing the same to WH Ireland as part of your correspondence with us but you should ensure that such information is only provided where it is absolutely necessary and in circumstances where you would be content for us to use it in the manner described above.
Right to access your personal data
You also have the right to request access to the personal data that we hold about you. Should you wish to request a copy of your personal data, or have any questions in relation to your personal data, please contact WH Ireland using the email address firstname.lastname@example.org.
Requests for access to your personal data will be processed free of charge. However, if we deem that requests for access are being made in a frequent, excessive and repetitive manner or on unfounded basis, WH Ireland reserves the right to charge a reasonable fee to meet our administrative costs.
Right to stop WH Ireland from using your personal data
You have the right to object to WH Ireland using your personal data or ask WH Ireland to delete, remove or stop using your personal data. You also have the right to restrict WH Ireland from using your data. This means that your personal data can only be used for certain things such as legal claims or in order to exercise legal rights.
During such instances, WH Ireland will not use or share your personal data in other ways. You may ask WH Ireland to restrict processing your personal data if it is not accurate; if it has been unlawfully used but you don’t want WH Ireland to delete it; if it is not relevant anymore but you want WH Ireland to keep it for use in legal claims; or you have already asked WH Ireland to stop using your data but you’re waiting for confirmation as to whether WH Ireland are allowed to use it. WH Ireland may need to keep or continue to use your data to comply with any regulatory reporting requirements or similar requirements.
Right to withdraw your consent
You have the right to withdraw your consent. Please contact WH Ireland if you wish to do so. Where consent is the only lawful basis upon which your personal data can be processed, withdrawing your consent may mean WH Ireland cannot provide you with a full service. If this is the case, WH Ireland will clarify this to you.
Right to rectify inaccurate personal data
You have the right to question any personal data we have about you that you think is wrong or incomplete. Should you do so, WH Ireland will take reasonable steps to check the accuracy of all information held and correct it where necessary.
Other Rights and Additional Information
Under the UK GDPR the rights you are provided with are: the rights to be informed, the right of access, the right to rectification, the right to erasure, the right to restrict processing, the right to data portability, (in some cases) the right to object, the right to withdraw consent and rights in relation to automated decision making and profiling. Key details of these rights are set out above. But full details of these rights are set out on the Information Commissioners website: https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
Right to complain
Please let us know if you are unhappy with how we have used your personal data. Contact details for all complaints can be found on our Complaints policy, available from our website: https://www.whirelandplc.com/complaints-handling-procedure.
You also have the right to complain to a supervisory authority if you consider the processing of the personal data relating to you infringes the UK GDPR. In the UK, the relevant supervisory authority is the Information Commissioner’s Office and further details of this process can be found on their website: https://ico.org.uk/make-a-complaint/.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within  one month. Occasionally it may take us up to three months to respond if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. Updates to this policy
We will occasionally update this Policy to reflect changes in the applicable Regulation, and / or relevant legislation as well as both company and customer feedback. We will contact you to inform you of the same whilst the revised Policy can be found on our website (https://www.whirelandplc.com/our-privacy-notices).