General Disclosures
Your information, our duty and your rights
To be our customer, you share information with us. To be your investment firm, we respect that information. On this page you will find out how we do that and what your rights are and how you can exercise them.
Right of Access to Information (Subject Access Request)
You can ask us for a copy of the personal information we hold and further details about how we collect, share and use your personal information.
You can contact us by your own preferred method.
You can request the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- where the personal data are not collected from the data subject, any available information as to their source;
Upon receipt of a subject access request we will contact you using our normal means of communication to ensure we provide you with exactly what you want via the means you require.
Updating and Correcting your Personal Details
If you want to update or correct any of your personal details, please contact us using the usual means or call us at 01 6670400.
Right to Restriction of Processing
You can request restriction of the processing of your personal information where one or more of the following apply:
- the information we hold is inaccurate (if you would like to correct any of your personal details, please call us on 01 6670400);
- we are processing your information unlawfully;
- we no longer require your personal information however you want us to retain your information for use in a legal claim;
- you have objected to the processing of your personal information based on our legitimate interests and want processing restricted while we consider whether we have overriding grounds to continue processing.
If you wish to request a restriction of the processing of your personal information based on the above criteria, you should advise us in writing and bring it along with a valid form of identification (current passport or drivers licence) to our offices Goodbody Stockbrokers UC, 9-12 Dawson St, Dublin 2 D02 YX99 or any of our branches.
In the event that you are unable to present your request in person, the request can be posted to Data Protection Officer, Goodbody Stockbrokers UC, 9-12 Dawson St, Dublin 2 D02 YX99 along with a certified copy of photo ID and certified copies of 2 proof of addresses (issued within the last 6 months) from independent sources. Your photocopies can be certified by a member of An Garda Síochána at your local Garda station, by a solicitor, an accountant, public notary or at your local bank branch.
Right to Object to Processing
You can request to object to the processing of your personal information where the processing:
- Is for the purpose of direct marketing (you can opt out of direct marketing at any time in person, through our client portal or by calling 01 6670400);
- Is carried out in the legitimate interests of us or third parties. Your right to object to processing based on legitimate interests will only be upheld if we can’t show compelling, legitimate reasons for the processing of your information which takes priority over your rights or we need to process it for establishment, exercise or defence of a legal claim.
- Is for scientific or historical research purposes
If you wish to object to the processing of your personal information based on the above criteria, you should advise us in writing and bring it along with a valid form of identification (current passport or drivers licence) to our offices Goodbody Stockbrokers UC, 9-12 Dawson St, Dublin 2 D02 YX99 or any of our branches.
In the event that you are unable to present your request in person, the request can be posted to Data Protection Officer, Goodbody Stockbrokers UC, 9-12 Dawson St, Dublin 2 D02 YX99 along with a certified copy of photo ID and certified copies of 2 proof of addresses (issued within the last 6 months) from independent sources. Your photocopies can be certified by a member of An Garda Síochána at your local Garda station, by a solicitor, an accountant, public notary or at your local bank branch.
Deleting your Information (Right to be Forgotten)
The Right to Erasure, also known as the Right to be Forgotten, permits you to request that we remove any personal information relating to you from our records if one or more of the following apply:
- your personal information is no longer required in relation to the purposes for which it was collected/processed;
- the processing was based on your consent, which you withdraw and there is no other legal basis for processing your personal information;
- you exercise your right to object and there are no overriding legitimate grounds for the processing;
- your personal information has been unlawfully processed; or
- your personal information needs to be erased to comply with a legal obligation.
To meet our legal, business and regulatory obligations, there are certain circumstances where we are required to retain your personal information. Examples of these circumstances include:
- Legislation/regulation requires the retention of information
- Your information is still subject to Goodbody’s Data Retention Schedule, which is the agreed period for which Goodbody Stockbrokers UC can store information on any account, product or application once it has been closed;
- You are still a customer with Goodbody and have open accounts that you are transacting on and products that you are using;
- You have an ongoing application with Goodbody for a product or account;
- You currently have a non-account holding relationship with the firm (e.g. trustee, guarantor, Power of Attorney, Assisted Decision Making Authority, Director of a Company, etc.); or
- If you are otherwise engaged with Goodbody, either directly or through a third party.
Where a right to be forgotten request has been upheld, the information we processed will no longer be linked to your identity.
If you wish to exercise your right to be forgotten based on the above criteria, you should advise us in writing and bring it along with a valid form of identification (current passport or drivers licence) to our offices Goodbody Stockbrokers UC, 9-12 Dawson St, Dublin 2 D02 YX99 or any of our branches.
In the event that you are unable to present your request in person, the request can be posted to Data Protection Officer, Goodbody Stockbrokers UC, 9-12 Dawson St, Dublin 2 D02 YX99 along with a certified copy of photo ID and certified copies of 2 proof of addresses (issued within the last 6 months) from independent sources. Your photocopies can be certified by a member of An Garda Síochána at your local Garda station, by a solicitor, an accountant, public notary or at your local bank branch.
Goodbody will only be able to forget accounts or products that are outside Goodbody’s Data Retention schedules and those that do not fall into our list of exemptions.
Right to Portability
You have the right to request your personal data held by us in a digital and portable format. Your portability request will include your personal information which has been:
- Processed automatically
- Processed with your consent
- Processed under the performance of a contract
- Provided by you (including observed usage of the account)
You can raise a Portability data request by:
- Advising us in writing at Data Protection Officer, Goodbody Stockbrokers UC, 9-12 Dawson St, Dublin 2 D02 YX99
- Phoning us at 01 6670400.
Goodbody will contact you to let you know that your request has been completed which will include instructions for collection. If an invalid request is submitted, Goodbody will contact you to let you know along with instructions of what is required to resolve the issue.
The digital portability file can only be collected by you or a nominated third party from one of our offices. Prior to collecting the data you or your nominated third party must present a valid form of ID and proof of address. Your file will be held for 28 days. If it is not collected during this time, the file will be securely destroyed
Data Protection Notice
This is our Data Protection Notice. Here we explain how we do the following:
- Use information relating to you,
- share information relating to you and
- keep the information that we hold about you and that relates to you.
This information is known as personal data and is referred to as “information” in this Data Protection Notice.
We must explain this to you under the General Data Protection Regulation (GDPR) and other data protection laws such as the Irish Data Protection Act 2018 (together Data Protection Law).
Data Protection Law:
- protects your information and
- tells us how we can use your information.
You can ask for more details about how we use your information by:
- calling us on 01 6670400
- emailing us at DPO@goodbody.ie (DPO stands for Data Protection Officer); or
- writing to us at Data Protection Officer, 9 – 12 Dawson Street, Dublin 2, D02 YX99.
You are responsible for ensuring the information relating to you that you give us is accurate, complete and up to date. If you give us information relating to another person (for example, a family member), you will need to tell them how to find this notice. You will also need to make sure they do not object to us using information relating to them as described in this notice.
Last updated: September 2026
Who we are
When we talk about ‘us’ or ‘we’, we are talking about Goodbody Stockbrokers Unlimited Company of 9-12 Dawson Street, Dublin 2, and the following Goodbody companies:
- Goodbody Stockbrokers UC in Ireland and the UK;
- Goodbody Securities Inc
- Gaiastream Ltd trading as Goodbody Clearstream
- Goodbody Pensioneer Trustees Limited
- Goodbody Stockbrokers Nominees Limited
This Data Protection Notice applies to you if your information is processed by any of the above companies.
The company making decisions in relation to your information is the controller of your information, and all references to “us” or “we” should be read as relating to that company.
Our Data Protection Officer is involved in and oversees how we collect, use, share and protect your information. You can write to our Data Protection Officer by:
- email: DPO@goodbody.ie, or
- post: Data Protection Officer, 9-12 Dawson Street, Dublin 2, D02 R126.
What information do we process about you?
Data Protection Law sets rules about how personal data can be used. Personal data means any information relating to living persons. As noted above, in this Data Protection Notice we refer to personal data as ‘information’.
Data Protection Law includes rules about how we can ‘process’ your information. When we use the words “process” or “processing”, we mean doing anything with your information, including collecting it, recording it, organising it, structuring it, storing it, sharing it and changing it.
Our products and services include discretionary, advisory and execution only investment services and financial planning services. To provide our products and services and to operate our business, we collect and keep information about you.
In some cases, providing your personal data to us is a contractual requirement or is necessary to enter into a contract with you. In some cases, providing your personal data to us is a statutory requirement. Without your information, we may not be able to offer you all our products and services and/or we may not be able to continue providing products and services to you.
The table below lists the categories of information about you that we may use. The table also explains the terms we use in this Data Protection Notice to describe your information:
| Category of Information | What type of information this includes |
| Personal | Information about you personally like your:
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| Contact details | Information about how to contact you:
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| Information on your Identity | Information that identifies you, such as your:
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| Information about your transactions | Information about how you use our products and services like:
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| Information about your personal circumstances | Information which tells us about your personal circumstances relevant to the products and services we are providing you, including:
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| Information about your location | Information which tells us:
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| Information from your mobile device or computer or use of our digital services | Information which tells us:
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| Market research | We may collect your information and feedback you provide when engaging in market research initiatives. |
| User login and access details | We process login details used to access our services via available platforms. |
| Communication records |
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Special category data
In addition to the above information, we may collect certain information about you that under Data Protection Law is called ‘special category data’.
Special category data includes:
- Race
- Ethnic origins
- Political opinions
- Religious or philosophical beliefs
- Trade union membership
- Physical or mental health
- Sex life and/or sexual orientation
- Genetic information
Examples of the types of special category data that we may process about you includes:
- Your physical or mental health information, where we are aware of a decision-making arrangement which relates to you.
- Your health information, where you have advised us that you need additional assistance or support and we may need to take this information into account to provide you with our products and services.
When we process your special category data, we will rely on one of the following exemptions as set out in Data Protection Law:
- Your explicit consent: In some circumstances, we will ask for your explicit consent to process your special category data. For example, where you provide us with information relating to your health as part of your engagement with us to support us in providing you with a product or service.
- Your vital interests or another person’s vital interests: In some circumstances, we may process your special category data where it is necessary to protect your vital interests or the vital interests of another person, where you are physically or legally incapable of giving your explicit consent.
- Substantial public interests: We may process your special category data where it is necessary for reasons of substantial interest, based on the laws of the EU or Ireland. For example, we may process information about your physical or mental health in the context of decision-making arrangements under the Assisted Decision-Making (Capacity) Act 2015.
- Legal claims or proceedings: We may process your special category data where necessary for the establishment, exercise or defence of legal claims.
How we collect your information directly from you
We collect information directly from you, such as when you interact with us online or in person and when you use our products and services and website. The following table lists information we collect directly from you:
| Source | Further Information |
| Account information | We collect information you give us when you apply for a service with us
We also collect information when you use our products and services, for example when you:
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| Phone Conversations | We sometimes record phone conversations to train our people, manage our records, improve services and offerings, and/or follow laws and regulations. In most instances, if we are recording a phone conversation we have with you, we will let you know in advance, for example at the start of the telephone call. |
| CCTV | We collect information through CCTV cameras at our offices. We use CCTV for the safety and security of our people, clients, members of the public, assets and buildings. |
| Websites and Cookies | We collect information about your use of our website. We also collect information through ‘cookies’ and similar technologies each time you visit our website. A ‘cookie’ (or other similar technology) is a text file that is placed on your device or accessed from your device and collects information about you and your device (such as remembering what you do on our website). Some cookies are strictly necessary for our website to work. Other cookies are not strictly necessary, and we will only deploy them where you give your permission to the use of such cookies. You can read more about our cookies on our Cookies Policy. |
| Other information you provide us | When you contact us through social media sites, we sometimes ask you for your phone number so we can contact you back if you have a problem or want to make a complaint.
If you contact us and provide us with additional information (for example, when making a complaint), we will collect and process this information. In some situations, you may provide us with information about other people (for example, where you apply for an account with another person, or in the context of a complaint). You should inform the other person that you are going to provide us with this information before you share the information with us, and you should make them aware of this Data Protection Notice. |
How we collect your information from others
We collect information about you from others. The following is how we collect such information about you:
Social media sites and other publicly available sources |
We collect information through social media sites, discussion forums, and market research to find out what people are saying about us.
We do not monitor specific persons on social media, and we can only see information that has been made publicly available on social media. The information we collect is used to provide a better service. We do not use the information we may see about you on social media to find out if you are a client |
| Other third parties | We may collect information about you from third parties in the context of the provision of our products and services, for example:
· If you are a company director, sole trader, or a business in partnership, we may collect information about you, and your company, from the Companies Registration Office (CRO). · From another financial institution, for example if you move your products and services to us from another financial institution. · Where we buy a business, or part of a business, from a third party. As part of a joint application the person applying for the service jointly with you may provide us with your information. |
| When you instruct us to deal with a third party on your behalf | Authorised Third Parties
· If you engage with us through a broker or other agent or representative, such as your accountant, we may share information with, and receive your information from, your representative. |
How we collect information about you if you are not a client
Sometimes we collect and use your information even though you are not a client of ours. Examples of this include when you are in the process of applying for an account or service with us, or when an account of yours moves from another investment firm to us before you become a client.
We also collect and use your information if you are connected to a client, for example if you are:
- A director of their company
- Part of a joint account and your account statements, with your information, are sent to us by our client as part of their application for a product or service.
Why we use your information
In this section, we tell you about why we use your information and the type of information we use in each case. Under Data Protection Law, we need a legal basis to use your information. This means that we must have a legal justification or reason to use your information. We rely on the following legal bases to process your information:
- Because we are entering into or have a contract with you and need to use your information to carry out that contract;
- To comply with laws and regulations;
- Where the processing is necessary for the performance of a task carried out in the public interest;
- Where you have given us your consent to do so;
- To protect the vital interests of you or another person; and/or
- For our legitimate interests, or the legitimate interests of a third party.
Further detail on Legitimate Interests
Legitimate interests mean our interests (or the interests of a third party, such as a shareholder) which we or the third party wish to achieve when we process your information. Before we process your information based on legitimate interests, we will assess whether the processing in question will adversely impact your rights and freedoms. Examples of legitimate interests include:
- Operating our business;
- Providing our services and products to you and our other clients;
- improving our products, services and our customer service, introducing new products and services; and
- Protecting our clients, employees and shareholders.
Further detail on Consent
We may ask you for your consent to use your information:
Sometimes we will ask you for your consent (permission) to process your information (including to send you marketing emails through channels such as email). You can manage your preferences at any time through our website or by contacting us. You will find more about this in the “Your rights” section of this Data Protection Notice.
If our processing of your information is based on consent that you give to us, you can change your mind about this any time and withdraw your consent. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before you withdrew it.
If we ever contact you to ask about ways to improve our products and services, it is up to you to decide if you want to answer or not.
Subject to applicable law, you can withdraw your consent at any time by:
- Contacting the Goodbody staff member you have been dealing with;
- Emailing the Data Protection Officer at DPO@goodbody.ie;
- Writing to us at Data Protection Officer, 9-12 Dawson Street, Dublin 2, D02 YX99;
- Updating your preferences in the website; or by
- Following the instructions in any message you receive.
You can read about the terms we use to describe your information here.
The table below provides more detail on why we use your information, the legal basis for doing so and information we use:
| Why we use your information | Legal basis for using your information | What information we use |
| To comply with laws and regulations
We use your information when required in order to comply with laws and regulations that apply to us. For example, we must comply with market abuse laws (Market Abuse Regulation), consumer protection laws (such as Consumer Protection Regulation, and MIFID), anti-money laundering laws (such as the Criminal Justice (Money Laundering) and Terrorist Financing) Act 2010), and assisted decision-making laws (the Assisted Decision Making (Capacity) Act 2015). We may in limited circumstances process criminal conviction data, where we are required or permitted to do so by EU or Irish law or regulation. This could arise, for example, for compliance with our anti-money laundering or countering the financing of terrorism obligations. |
· To comply with laws that apply to us (legal obligation). | · Personal, contact details and information on your identity
· Information about your transactions · Information about your personal circumstances |
| To check your identity and other details with the aim of preventing fraud
We will use your information to conduct various checks in connection with your use of our products and services, such as to verify your identity, address, and where your money comes from. This may include:
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· To comply with laws that apply to us (legal obligation).
· For the legitimate interests in helping to protect our business and clients. These checks help to maintain the safety, integrity, and lawful use of our products and services. |
· Personal, contact details and information on your identity
· Information about your transactions |
| To assess your eligibility for products and services
We will use your information to assess your suitability /eligibility for, and to provide, products and services that are suitable for you. For example:
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· To comply with laws that apply to us (legal obligation).
· To take steps prior to entering a contract with you (contractual necessity). · For the legitimate interests in offering products and services that are suitable and relevant to you. This helps us to ensure that we provide appropriate and responsible financial products and services to our clients. |
· Personal, contact details and information on your identity
· Information about your transactions · Information about your personal circumstances · Communication records |
| To understand your financial needs and to improve our products and services
We will use your information to understand your financial needs and to improve our products and services to better understand what you like and want from us, including, for example, to carry out surveys. For example:
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· For the legitimate interests in conducting and managing our business and help to ensure that we are delivering suitable and appropriate products and services to our clients. |
· Communication records · Information from your mobile device or computer or use of our digital services |
| To manage and maintain your products and services
We will use your information to maintain your products and services and monitor their usage. For example:
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· To comply with laws that apply to us (legal obligation).
· For the legitimate interests in understanding your financial needs and improving our products and services. These activities help us to provide products and services and communications that better meet your requirements. · To perform the contract we have with you (contractual necessity). |
· Communication records |
| To help to protect you and our business against criminal activity such as fraud and scams
We will use your information to help to protect you, your money and our business from financial crime and fraud and scams. For example:
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· To comply with laws that apply to us (legal obligation).
· For the legitimate interests in helping to protect you and our business from crime, fraud and scams. These measures are aimed at helping to protect your assets and ensure the integrity of our products and services. |
· Communication records |
| To analyse client behaviour and service usage for consideration with respect to business decisions
We will use your information to understand trends regarding our products and services. For example:
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· For the legitimate interests in understanding client behaviour and service usage to support informed business decisions. This helps us improve our existing products and services and assists with preparing future offerings that are relevant and useful to our clients.
· You give us your permission (consent). |
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| To personalise your experience and send marketing communications to you
We will use your information to understand how you use our products and services, and how well we meet your expectations. |
· You give us your permission (consent).
· For the legitimate interests in understanding how you use our products and services and how we meet your needs and expectations. This helps us provide communications and offerings that are relevant and useful to you. |
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| To manage operational and compliance risks to protect our clients, employees, and shareholders
We will use your information to identify, manage and mitigate various risks, so we can protect:
This may include using your information when required to identify, manage and protect against risks that arise for our clients and the firm, including creating management information to allow us to provide assurance in the areas of compliance with regulatory and legal obligations, adherence to operational processes, and to manage our network and information security. |
· For legitimate interests in identifying, managing and mitigating operational and compliance risks. This helps to support the safe and responsible delivery of our products and services to our clients and helps to support the proper functioning of financial services in Ireland.
· To comply with laws that apply to us (legal obligation). |
· Communication records |
| Marketing our products and services that we think may be relevant and useful to you.
We will use your information to market our products and services that may be interesting and relevant to you. For example, to show you a marketing message. You can manage your preferences at any time by contacting us. |
· You give us your permission (consent).
· For legitimate interests in promoting our products and services to you and offering products and services that we consider are likely to be of relevance and useful to you. |
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| To detect false or misleading information.
We will use your information to decide if we have been given false or misleading information and if we suspect criminal activity. |
· To comply with laws that apply to us (legal obligation).
· For legitimate interests to help to ensure and maintain the integrity of our products and services, help to protect our clients and business and comply with legal and regulatory obligations. This also helps to support the proper functioning of financial services in Ireland. |
· Communication records |
| To enable secure access to digital services.
We will use your information to confirm your identity so you can access our services through the technology available on devices more quickly. |
· You give us your permission (explicit consent).
· To perform the contract we have with you (contractual necessity). |
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| To deliver products and services with partners and joint ventures.
We will use your information to deliver products or services that we provide with companies with whom we have a joint venture or working agreement, such as insurance providers. For example, we may share information with these companies where there is a joint venture or working agreement to allow us offer our clients certain products and services, to enhance the product offerings we have available, and to support clients with queries and complaints. |
· To perform the contract we have with you (contractual necessity).
· For legitimate interests in delivering products and services through our partners and joint ventures. These collaborations help us to better serve our clients through enhanced services, support, client dealings and enhanced product offerings · You give us your permission (explicit consent). |
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| To facilitate business transfers.
We will use your information if we are going to sell the whole or part of our business, or in connection with the sale, securitisation, merger, liquidation, receivership of all or part of our assets. |
· For legitimate interests in ensuring the facilitation of business changes such as transfers. |
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| To manage legal claims and disputes.
We will use your information to protect our legal rights and interests, and the legal rights and interests of others. This includes to prepare and progress litigation claims or proceedings taken (or anticipated) by or against us (including for insurance claims management) or respond to complaints, investigations or other regulatory processes involving Goodbody. This could be in connection with any legal proceedings, claim or dispute that might arise in connection with our relationship with you, our service(s), people, property or assets and may include sharing information within our Group. |
· To comply with laws that apply to us (legal obligation).
· For legitimate interests in managing legal claims and disputes to protect our rights and interests and those of others. · Where necessary for the establishment, exercise or defence of legal claims. |
· Communication records |
| To support vulnerable clients or in the case of emergencies.
We will use your information to ensure we can provide you with our products and services if you are a vulnerable client or (in rare circumstances) if we think you or another person needs urgent assistance. |
· To comply with laws that apply to us (legal obligation).
· To protect the vital interests of you or another person · Substantial public interest. |
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| To manage complaints and respond to regulatory investigations. | · To comply with laws that apply to us (legal obligation).
· For legitimate interests in managing complaints, responding to regulatory investigations and defending our rights and interests. This includes using your information to handle client concerns, cooperate with regulators and support any necessary inquiries or reviews. These activities help us maintain transparency, accountability and compliance with legal obligations. |
· Personal, contact details and information on your identity
· Information about your transactions · Communication records |
| To audit our business and ensure compliance with legal and regulatory standards. | · For legitimate interests, so that we can conduct and manage our business effectively and efficiently and ensure that resources are allocated appropriately. These activities help us operate responsibly and protect our clients, employees and stakeholders.
· To comply with laws that apply to us (legal obligation). |
· Personal, contact details and information on your identity
· Information about your transactions · Communication records |
| To use cookies and similar technologies to personalise your experience and improve our products and services. | · You give us your permission (consent). |
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| To send out communications including statements and communications required under financial regulations. | · To comply with laws that apply to us (legal obligation).
· For our legitimate interests in maintaining transparent and compliant client communications and ensuring that our clients are appropriately informed. |
· Personal, contact details and information on your identity
· Information about your transactions |
| To respond to and fulfil requests made by individuals in relation to their data protection rights, such as access, rectification, erasure or data portability. | · To comply with the laws that apply to us (legal obligation). | · Personal, contact and information on your identity
· Information about your transactions · Communication records · Any other data that is relevant in respect of the request |
| To comply with legally binding court orders or warrants issued in the context of civil or criminal proceedings, which may require us to disclose personal data to relevant authorities or parties. | · To comply with the laws that apply to us (legal obligation). | · Personal, contact and information on your identity
· Information about your transactions · Communication records · Any other data that is relevant in respect of the order |
| To provide you with relevant informational and educational communications.
We may use your information to send you market insights, investment commentary, educational content and information relevant to your existing relationship, products or services. These communications are intended to help you stay informed and support your investment decision-making. |
· You can unsubscribe or object to receiving these communications at any time |
· Personal and contact details
· Information about your existing relationship with us · Products or services you hold · Communication preferences and history |
We share your information within the Goodbody Group and with others, see the “How we share your information within Goodbody” and “How we share information with third parties” sections below for details.
How long we keep your information for
We keep your information as long as necessary for the purposes for which it is processed. We keep your information while you are a client with us and after that for as long as required or permitted for legal or regulatory reasons, or for our legitimate business purposes, such as to deal with any claim or dispute. We also keep your information when you engage with us about a product or service, but you are not provided with the product or service. We hold this information for as long as required for legal or regulatory reasons, or for our legitimate business purposes.
The length of time we keep your information for depends on factors such as:
- the type of service or accounts we have provided to you;
- our need to comply with legislation, for example to comply with anti-money laundering laws;
- our need to comply with other regulatory rules, for example, the rules contained in the Markets in Financial Instruments Directive (MiFID) and subsequent iterations of same, Consumer Protection Regulations or rules of the Financial Service and Pensions Ombudsman;
- to resolve complaints;
- to prevent fraud or scams;
- to protect our business;
- our need to comply with regulatory investigations;
- if there are or may be ongoing or prospective legal proceedings between us, or with third parties.
How we share your information within Goodbody
We share your information within Goodbody, our parent AIB Group and its subsidiaries to help us:
- provide our products and services;
- verify your information;
- protect our interests in the context of (or in anticipation of) legal claims or proceedings;
- improve our products and services; and
- follow laws and regulations.
How we share information with third parties
We share your information with third parties to help us to provide our products and services to you, to manage our business more efficiently and for legal and regulatory reasons. You can read more about the information we share with third parties in the table on the following section.
- Click here to read about how we describe your information.
| Who we share your information with | Why we share it | What we share | Lawful basis for sharing your information |
| Asset management firms that manage funds for people and companies. |
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| Companies who provide support services to us, such as Information Technology (IT), software services and maintenance providers, telecommunications providers, cloud software and storage providers, and document storage and printing providers. |
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| Market research companies. |
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| Research and analytic companies that study trends and patterns. |
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| Financial advisors and service providers. |
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| Insurance companies. |
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| Law enforcement agencies, government bodies. |
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| Payment software providers such as online payment providers. |
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| Auditors. |
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| Consultants. |
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| Legal advisors. |
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| Companies (and their advisors) who express an interest in buying part or all our business, including in connection with the sale, securitisation, merger, liquidation, or receivership of all or part of our assets. | · To transfer your accounts to another service provider.
· To assess value, to perform due diligence. · To facilitate the ongoing management of assets. |
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| Regulators such as the Data Protection Commission, Central Bank of Ireland, European Central Bank and the European Securities & Markets Authority. |
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| Trading Venues
(that is, facilities where securities are traded, including markets such as stock exchanges) |
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| Security operations providers who provide us with security services for our premises and other facilities. |
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| Security trustees, for example a person or company that manages property, assets for a third party or pension fund managers. |
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| Joint venture companies, that we work with. |
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How we send your information outside the European Economic Area (EEA)
Sometimes, to provide our products and services we will send your information outside the European Economic Area (EEA). In addition, some of our service providers (such as IT service providers and payment processors), contractors and other third parties used to help us provide your products and services are based outside of the EEA. The EEA means the countries in the European Union, Norway, Iceland and Liechtenstein.
We will only send your information to non-EEA countries (such as the UK, the U.S. and India) where one or more of the following applies:
- Where the European Commission has decided that the non-EEA country has an adequate level of protection in place to protect your information. (The European Commission adequacy decisions are available here).
- Where the European Commission approved “Standard Contractual Clauses” or “SCCs” are included in our contracts with the organisation in the non-EEA country receiving your information, to ensure that appropriate safeguards are in place to protect your information and your rights in relation to your information. The European Commission SCCs are available for review here with copies of specific SCCs available on request from our DPO.
- In limited situations, where an exception permitting the transfer applies under the GDPR, such as:
- You have given your explicit permission for the transfer of your information to the non-EEA country.
- The transfer is necessary to perform our contract with you.
- The transfer is necessary for important reasons of public interest.
- The transfer is necessary to establish, exercise or defend legal claims.
- The transfer is necessary to protect your vital interests or the vital interests of another person.
- We also take measures to ensure that further transfers of information (for example from our service provider to its service provider or group company located outside of the EEA) are carried out in compliance with Data Protection Law.
Your rights
Under Data Protection Law, you have rights about your information. You have the right to:
- access your information and to receive a copy of your information.
- object to processing of your information on grounds relating to your particular situation (where we process your information on the basis of “legitimate interest”). For example, you can opt-out of marketing messages delivered based on our legitimate interests, by contacting us.
- have your information updated and corrected, where it is incorrect.
- have the processing of your information restricted.
- have your information that is stored electronically transferred to you.
- have your information deleted.
- withdraw your consent where we are using your information on the basis of your consent (for example, you can tell us not to send you marketing emails). Please note that the withdrawal of consent does not affect the lawfulness of processing based on consent prior to the withdrawal of consent.
- not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (subject to certain exceptions).
- complain to the Data Protection Commission. Details in respect of this are set out in the ‘If you want to make a complaint’ section below.
Please note that the exercise of the above rights is subject to applicable law. Data Protection Law includes exceptions to the above rights. For example, the rights available to you may depend on our legal basis relied upon for processing your information. More detail on your rights and how to exercise them can be found here, or by referring to the ‘Contact us’ section below.
We are obliged to respond without undue delay, in most cases within one month of your request. In certain circumstances this period may be extended by a further two months, for example if we cannot fully respond within one month due to the complexity or number of requests.
Marketing Preferences
Please be aware that changes to your marketing preferences may take a short time to process. During this period, you might still receive marketing messages.
Additionally, opting out of marketing will not affect our ability to send you essential service updates, such as changes to your account terms or notifications that we are required to send by law.
Contact us
You can exercise your rights through forms available on our website https://www.goodbody.ie/legal-and-regulatory-disclosures/ In addition, if you have any queries on any aspects of this data protection notice, you may contact us:
- by contacting your Relationship Manager/ Goodbody contact by phone, post or e-mail
- by emailing us at DPO@goodbody.ie
If you want to make a complaint
If you are unhappy with the way we process your information including how we collect, use, keep and share it, you have the right to lodge a complaint with our supervisory authority, the Data Protection Commission through its website www.dataprotection.ie or by writing to the Data Protection Commission at 6 Pembroke Row, Dublin 2, D02 X963, Ireland. We ask that you contact us in the first instance to give us the opportunity to address your concerns.
If you are unhappy with the way we collect, use, keep and share your information, please tell us. This can be done via email, letter or phone call to your Relationship Manager/point of contact within Goodbody.
- calling us on 01 6670400
- emailing us at DPO@goodbody.ie (DPO stands for Data Protection Officer); or
writing to us at Data Protection Officer, 9 – 12 Dawson Street, Dublin 2, D02 YX99.
Wealth Management
Client Forms
Source of Wealth & Source of Funds Declaration Form
As part of our ongoing regulatory obligations, we periodically ask clients to confirm their source of wealth and the origin of funds invested with us. This secure online form allows you to provide the required information and supporting documentation quickly and easily.
Stock Forms
This form is used for the sale of certificated Irish and UK stock only.
This form is used for the transfer of ownership of certificated Irish stock.
This form is used for the transfer of ownership of certificated UK stock.
This stock power form is used to give authorisation from the holder of US or Canadian certificated stocks to a broker to either sell or dematerialise his stock. A stock power, when signed, will supersede any information already entered onto the back of the certificate by the client. Therefore, if any mistakes are made when signing or filling out the back of the certificate, these can be overridden by the use of a stock power.
In order for a stock power form to be valid, the signature must be legible and match exactly the name on the front of the certificate. Thus a client must sign in his/her full name if this is how it appears on the certificate. For example, if an initial ‘J’ appears on the Certificate the signature should also include the ‘J’
Foreign Certificate Validation Form
View/Download the Foreign Certificate Validation form.
Tax Related Forms
W9 form – Request for Taxpayer Identification Number and Certification
Those who are US residents, citizens, born in the US, greencard holders or passport holders will need to fill out this form before opening a sharedealing account with Goodbody Stockbrokers. Supplied in Adobe PDF format.
Instructions for completing W9 Form.
This form is for persons resident in a country who are not passport holders of that country, excluding US persons. It allows you to avail of lower tax rates on US dividends only.
Instructions for completing W-8Ben Form.
This form is for entities to establish their status for the purpose of withholding tax and reporting. It also allows the account holder to avail of lower tax rates on US dividends.
Instructions for completing W-8Ben-E Form.
View/Download the Entity Self-Certification.
Information on Funds
Investment Banking
Conflicts of Interest Policy Related to the Production of Investment Research Reports
Introduction
This policy sets out the measures adopted by Goodbody Stockbrokers (the “Firm”) to ensure the objectivity and impartiality of its Capital Markets investment research. It has been prepared for information purposes for the Firm’s clients and other interested parties. More detailed internal policies and procedures with which all relevant staff are required to comply support this policy.
Goodbody Stockbrokers UC, trading as Goodbody, is regulated by the Central Bank of Ireland and Goodbody Stockbrokers UC is authorised and regulated in the United Kingdom by the Financial Conduct Authority. Goodbody is a member of Euronext Dublin and the London Stock Exchange. Goodbody is a wholly owned subsidiary of Allied Irish Banks, p.l.c. Registered Office: 9-12 Dawson Street, Dublin 2, D02 YX99. Tel:+353 1 667 0400; Registered In Ireland: Registration No. 54223.
Nature of Investment Research
The Capital Markets Research department provides research coverage on most securities listed on the Irish Stock Exchange, Irish Issuers listed on other markets and other issuers which in the opinion of the Head of Research, are likely to be of significant interest to our clients. The department also provides sectoral coverage relevant to issuers covered by Goodbody Stockbrokers and macroeconomic analysis.
Law and Regulation
Written Institutional Research is prepared for the use of institutional investors and emailed to those clients. Research activities are carried out in accordance with all applicable laws and regulations, and must not be carried out in a manner which the Researcher knows or should know to be likely to put any other person at significant risk of acting in an unlawful manner or in breach of the rules or regulation applicable to that person. Researchers are expected to be aware of the laws and regulations applicable to their work and to seek advice from the Head of Research or the Compliance Department in cases of doubt. Researchers are also expected to act in a manner, which promotes high standards of ethical behaviour and professionalism.
Independence
Goodbody policy is that the views expressed in research pieces must be independent and in particular must not take into account any business relationship or interest which Goodbody Stockbrokers may have or any conflicting personal interests. No person is authorised to put direct or indirect pressure on an Analyst to change his opinions or the manner in which they are expressed or to take action of any type against an Analyst because of the expression of views which do not coincide with Goodbody Stockbrokers.
Analysts are not permitted to hold external positions (i.e. appointment to a board of Directors, as an officer or its equivalent) the nature of which might compromise their independence. All external positions must be approved by Compliance In common with other staff of Goodbody Stockbrokers, Analysts are prohibited from accepting any gift or inducement, which could call into question their integrity or independence. This does not preclude acceptance of reasonable corporate hospitality in common with the Firm’s general policies on gifts and benefits.
Information Barriers
The Firm has formal policies relating to the maintenance and operation of Information Barriers procedures. These procedures generally enable research coverage and trading to continue in circumstances where, in the absence of such procedures, insider dealing and market abuse legislation would prevent Goodbody Stockbrokers from trading in or covering the stock. Under no circumstances are Analysts to seek to directly or indirectly obtain unpublished confidential information which is material to a listed company. Research Management has to pre-approve any request by Investment Banking staff to bring an Analyst over the wall to ensure the Analysts activities are managed to avoid actual or potential conflicts with other activities that the Analyst may be involved in.
Management and Supervision Arrangements
The Capital Markets Research department operates as an independently managed department. All Research Analysts, report to the Head of Research. The Head of Research reports into the Head of Capital Markets who in turn reports into the Managing Director. Analysts do not report to, and are not supervised by, personnel in any other department, including Corporate Finance The Head of Research is responsible for allocating coverage of issuers among the research team and for ensuring that appropriate arrangements are in place to clearly identify responsibility for any given piece of research and for ensuring that appropriate arrangements are in place for the preparation, review and issuance of research.
Remuneration of Research Analysts
Similar to all other staff members of the Firm, Analysts remuneration consist of an annual salary together with bonuses based on both the Firm’s profitability and the individual performance. Factors which may be taken into account when determining remuneration include the individuals productivity and performance, the overall quality of their research, feedback and evaluation from the Firm’s institutional clients and sales team and the Firm’s overall performance and profitability. No Analyst is remunerated on the basis of involvement in any particular transaction or for any particular piece of work.
Personal Account Dealing
Research Analysts are not permitted to deal for their own account or that of their immediate family, in any securities of the companies they cover save in limited cases relating to holdings which existed prior to the introduction of Goodbody Stockbrokers Capital Markets Research policy or the date the Analyst commenced coverage of the stock. Analysts holding shares in companies, which they do not cover, are subject to the Firm’s normal staff dealing rules.
Restrictive Activities
Analysts are not permitted to participate in efforts to solicit investment-banking business or attend any company or investment-banking business sponsored road shows, related to a public offering or secondary fundraising. In general, where Goodbody Stockbrokers are acting in connection with an Initial Public Offering or a large secondary offering, research cannot be issued for a set period of time. Researchers will however meet companies including corporate clients separately in the normal performance of their duties.
Discontinuation of Coverage
In the rare event that the Firm discontinues coverage of a stock, (other than a delisting) it will be disclosed in the Firm’s monthly book citing the rationale for such termination.
Disclosures
All Institutional Equity Research publications contain required general and specific disclosures.
Conflicts of Interest
Goodbody has procedures and policies in place to identify and manage any potential conflicts of interest that arise in connection with its research business. Goodbody analysts and other staff who are involved in the preparation and dissemination of research operate and have a management reporting line that is independent to its business. Information barriers are in place between the Corporate Finance arm and the Research arm to ensure that any confidential and or price sensitive information is handled in an appropriate manner.
Our Investment Research Conflicts of Interest Policy is available at Conflicts of Interest. Investors should be aware, that, where appropriate, research may be disclosed to the issuer(s) in advance of publication, in order to correct factual inaccuracies only and not to materially amend the research in any way. Goodbody is satisfied that it has operational procedures in place, which ensure that such disclosures will not compromise the report’s objectivity.
Goodbody Stockbrokers is a registered market maker in the majority of companies listed on the Irish Stock Exchange and their equivalent on the London Stock Exchange and may hold positions in any of the companies mentioned in this report from time to time. The list of companies for which Goodbody acts as market maker and on which it provides research, is available at Regulatory Disclosures. We would like to inform you that Dudley Shanley holds shares in Ryanair and Wizz Air.
Goodbody has provided investment banking services to AIB Group, Applied Nutrition, Cairn Homes, CRH, Datalex, FD Technologies, Grafton Group, Greencore, Hammerson, Hostelworld, ICG, Kingspan, Lunglife AI, Molten Ventures, Origin Enterprises, Playtech, Rank Group, Ryanair, Bank of America Merrill Lynch, Flutter Entertainment, Natwest, Accorinvest, Wells Fargo, PTSB, Barclays, ING Groep NV, Smurfit Westrock, UBS, Morgan Stanley, Goldman Sachs and JP Morgan, Clorox, NTMA, BNP in the past 12 months.
Goodbody Stockbrokers UC acts as corporate broker to AIB Group, Applied Nutrition, Cairn Homes, CRH, Grafton Group, Greencore, Hostelworld Group, ICG, Kingspan, Origin Enterprises and Ryanair.
Other Disclosures
A description of this company is available at Company Descriptions. All prices used in this report are as at close of business of the previous working day unless otherwise indicated.
A summary of our standard valuation methods are available at Valuation Methodologies. A summary of share price recommendations and whether material investment banking services have been provided to these companies is available at Regulatory Disclosures. Other important disclosures are available at Regulatory Disclosures. Goodbody updates its recommendations on a regular basis. A breakdown of all recommendations provided by Goodbody is available at Regulatory Disclosures. Where Goodbody has provided investment banking services to an issuer, details of the proportion of buys, holds and sells attributed to that issuer will also be included. This is updated on a quarterly basis.
The date on which stock recommendations were first released for all stocks mentioned in this report are available at Regulatory Disclosures. If a different recommendation has been made in the previous twelve months, this will also be disclosed here.
Recommendation Definitions
Goodbody uses the terms “Buy”, “Sell” and “Hold. The term “Buy” means that the analyst expects the security to appreciate in excess of 10% over a twelve month period. The term “Sell” means that the security is expected to decline in excess of 10% over the next twelve months. The term “Hold” means that the analyst expects the security to neither appreciate more than 10%, or depreciate more than 10% over the next twelve months.
On 26th November, 2012, the terms “Add” and “Reduce” were removed from the Recommendation Definitions and both were replaced with the “Hold” recommendation. Any Previous Recommendation that refers to either an “Add” means that the analyst expected the security to appreciate by up to 15% over a twelve month period. Any Previous Recommendation to “Reduce” means that the analyst expected the security to decline by up to 15% over the next twelve months.
In the event that a stock is delisted the firm will automatically cease coverage. If however the firm ceases to cover a stock for any other reason the firm will disclose this fact.
Goodbody Stockbrokers UC is an unlimited company registered in Ireland. The firm’s head office is based at 9-12 Dawson Street, Dublin 2, D02 YX99, Ireland. The firm’s issued share capital is €10 million. The firm is not subject to any insolvency or analogous proceedings.
GSI distributes third-party research produced by its affiliate, Goodbody.
GSI is a member of FINRA and SIPC.
GSI does not act as a market-maker.
An affiliate of GSI may have acted, in the past 12 months, as lead manager/co-lead manager of a publicly disclosed offer of the securities in this company. Investors should be aware that an affiliate of GSI may have provided investment banking or non-investment-banking services to, and received compensation from this company in the past 12 months or may provide such services in the next three months. The term investment banking services includes acting as broker as well as the provision of corporate finance services, such as underwriting and managing or advising on a public offer. All transactions by US persons involving securities of companies discussed in this report are to be effected through GSI.
Regulatory Information
Goodbody Stockbrokers UC, trading as Goodbody, is regulated by the Central Bank of Ireland and Goodbody Stockbrokers UC is authorised and regulated in the United Kingdom by the Financial Conduct Authority. Goodbody is a member of Euronext Dublin and the London Stock Exchange. Goodbody is a wholly owned subsidiary of Allied Irish Banks, p.l.c. This publication has been approved by Goodbody. The information has been taken from sources we believe to be reliable, we do not guarantee their accuracy or completeness and any such information may be incomplete or condensed. All opinions and estimates constitute best judgement at the time of publication and are subject to change without notice. The information, tools and material presented in this document are provided to you for information purposes only and are not to be used or considered as an offer or the solicitation of an offer to sell or to buy or subscribe for securities.
Goodbody Stockbrokers is a registered market maker in variety of companies listed on Euronext Dublin and the London Stock Exchange and may hold positions in any of the companies mentioned in this report from time to time. The list of companies for which Goodbody acts as market maker and on which it provides research, is available at Regulatory Disclosures.
Disclaimer for recipients of research reports.
While all reasonable care has been taken in the production and dissemination of this report it is not to be relied upon in substitution for the exercise of independent judgement. Nothing in this report constitutes investment, legal, accounting or tax advice, or a representation that any investment or strategy is suitable or appropriate to your individual circumstances, or otherwise constitutes a personal recommendation to you.
Private customers having access, should not act upon it in anyway but should consult with their independent professional advisors. The price, value and income of certain investments may rise or may be subject to sudden and large falls in value. You may not recover the total amount originally invested. Past performance should not be taken as an indication or guarantee of future performance; neither should simulated performance. The value of securities may be subject to exchange rate fluctuation that may have a positive or adverse effect on the price or income of such securities.
All material presented in this report, unless specifically indicated otherwise is copyright to Goodbody. None of the material, nor its content, nor any copy of it, may be altered in any way, transmitted to, copied or distributed to any other party, without the prior express written permission of Goodbody.
Information regarding communications from Goodbody Capital Markets Sales or Specialist Sales Teams.
Any commentary received from the Goodbody Capital Markets Sales team or Specialist Sales Team should be regarded as a marketing communication as described in Article 36 of Commission Delegated Regulation (EU) 2017/565.
Publications received from the Goodbody Capital Markets Sales team or Specialist Sales team do not constitute investment research and should not be regarded as being objective or independent. Such publications are not prepared in accordance with the legal requirements designed to promote the independence of investment research and are not subject to any prohibition upon dealing ahead of their dissemination. Communications from Goodbody Sales or Specialist Sales are not prepared in accordance with conflicts of interest requirements relating to the objective production of investment research.
Material received from Goodbody Sales or Specialist Sales teams is intended for the sole use of the person or firm to whom it is provided and is for discussion purposes only. It is not intended for further dissemination in its present form and may not be disseminated to other parties.
n the event of any significant business disruption, Goodbody has in place a business continuity process to ensure that we can maintain continuity of services for our clients. In the event of any such disruption you can contact us as you usually do on our main phone line +353 1 667 0400. We can also be contacted by email at goodbody@goodbody.ie
Goodbody Stockbrokers apply a range of valuation methodologies in the production of Equity Research, within which the following are the main methods adopted:
1. Share-based multiples include:
- Forward price/earnings (P/E) ratios, based on adjusted earnings.
- Forward price/cash-earnings ratios
Price to net asset value (NAV) per share and - Dividend yields.
2. Enterprise-based valuation multiples include:
- Forward earnings before depreciation, interest, tax, depreciation or amortisation (EBITDA) ratios;
- forward operating cash-flow ratios
Enterprise value (EV)/sales ratios; and - EV/invested capital ratios.
3. Cyclical consideration
In the case of average earnings multiples, consideration is given to the stage of the relevant industry cycle, as it may not be appropriate to apply average multiples towards the peak or trough of a cycle. In such cases, earnings multiples prevailing at the corresponding stages of previous cycles may be used.
4. Asset based valuations
In the case of asset-based valuations, reported tangible net assets generally provide a floor to a company’s valuation. However, in many cases, company financial statements can understate the underlying economic value of a company’s assets and a ratio such as return on invested capital to weighted average cost of capital (ROIC/WACC) may provide a more appropriate indicator of the book value multiple.
5. Company comparisons
The ratings of similar companies (peer groups) may be taken into account as a proxy for the average ratings for particular industry sectors. Such ratings are commonly used in analysts’ sum-of-the-parts (SOTP) valuations.
6. Cashflow based valuation
In discounted cash-flow (DCF) models a company’s forecast future free cash-flows are discounted by its weighted WACC. However, due to the inherent uncertainties involved in forecasting long-term cash-flows, analysts tend to adopt a range of both WACC and terminal values within the DCF models, producing a range of alternative valuations.
7.Other valuation techniques
In some instances, other valuation metrics may be used. For instance, for airlines metrics per passenger and / or available seat kilometre flown may be used for inter-company and valuation purposes.