Goodbody Privacy Notice

Privacy Notice – General users and clients

Introduction

Goodbody takes your privacy very seriously. This Privacy Notice sets out how we collect and process your personal data, explains your rights and answers any queries you may have about your personal data.

If you have entered into a contract with us or one of our subsidiaries or group companies, the controller of your data will be Goodbody Stockbrokers UC and its associated companies (collectively and individually, as appropriate, "Goodbody", "we", or "us").

Our personal information handling policy and procedures have been developed in line with the requirements of the General Data Protection Regulation (in force from 25 May 2018) and applicable national law.

1. WHAT INFORMATION DO WE COLLECT AND PROCESS?

We collect and process personal data about you when you engage with Goodbody either as a client or as a potential client.

We collect and process personal data about you when you interact with us and our products and when you engage us to act on your behalf. The personal data we process may include any or all of the following:

  • your name;
  • your Goodbody Online username and password;
  • your home or work address, email address and/or phone number;
  • utility bills or other forms of address verification;
  • your job title;
  • your bank details;
  • your PPSN number;
  • your financial situation information including all forms of income and remuneration;
  • your passport or other forms of identity verification;
  • information related to the browser or device you use to access our website;
  • internet browser and operating system;
  • recordings of calls you make to our client representatives; and or
  • any other information you provide which is relevant to the service being provided.

We will not seek to gather any personal data which is not relevant for the provision of a service or an ancillary activity that we provide.

2. HOW DO WE USE THIS INFORMATION AND WHAT IS THE LEGAL BASIS FOR THIS USE?

We process the personal data listed in paragraph 1 above for the following purposes:

  • to establish and fulfil a contract with you, for example, if you make a purchase from us or enter into an agreement to provide or receive services; this may include verifying your identity, taking payments, communicating with you, and providing client services otherwise we would be unable to enter into a contract with you.
  • to comply with applicable law and regulation;
  • in protecting Goodbody's legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation);
  • with your express consent to respond to any comments or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our website or our products or services;
  • we may use information you provide to personalise (i) our communications to you; (ii) our website; and (iii) products or services for you, in accordance with our legitimate interests;
  • to monitor use of our websites and online services. We may use your information to help us check, improve and protect our products, content, services and websites, both online and offline, in accordance with our legitimate interests;
  • we may monitor any client account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law and our legitimate interests;
  • in circumstances where you contact us by telephone, calls may be recorded for quality, training and security purposes, in accordance with our legitimate interests; and
  • we may use your information to invite you to take part in market research or surveys.

We may also send you direct marketing in relation to relevant products and services. Electronic direct marketing will only be sent where you have given your consent to receive it, or (where this is allowed) you have been given an opportunity to opt-out. You will continue to be able to opt-out of electronic direct marketing at any time by following the instructions in the relevant communication.

3. WITH WHOM AND WHERE WILL WE SHARE YOUR PERSONAL DATA?

Your personal data is highly confidential and will be stored securely with access to it restricted to those who need to use it for legitimate legal and business purposes. In certain circumstances we may be obliged to share your personal information with third parties. These circumstances may include, but are not limited to, circumstances where we use third party service providers to assist us in providing services to you, where it is required by a settlement services provider and other agents of yours or ours, to comply with any legal or regulatory requirement, to carry out our obligations under our Terms and Conditions or any relevant Agreement with you, as well as to protect and defend the rights of property of Goodbody, our licensors and/or our other clients. In all other circumstances, we will only share information with third parties with your written consent.

Some of the third parties that we may be required to share your personal data with include:

  • Pershing Securities International Ltd to whom we have outsourced our clearing and settlement processes;
  • The Central Bank of Ireland;
  • The Pensions Authority;
  • Irish Stock Exchange;
  • London Stock Exchange;
  • Financial Services and Ombudsman Bureau of Ireland (in the case of a dispute); and
  • third party service providers such as insurance companies and banks.

4. HOW LONG WILL YOU KEEP MY PERSONAL DATA?

We will not keep your personal information for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose for which it was acquired. We are also required to retain certain information under legislation or to meet our regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

Where you are a client, we will keep your information for the length of any contractual relationship you have with us and after that for a period of 6 years.

Where you are a prospective client and you have expressly consented to us contacting you, we will only retain your data (a) until you unsubscribe from our communications; or, if you have not unsubscribed, (b) while you interact with us and our content; or (c) for 12 months from when you last interacted with us or our content.

We will retain your data for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place. In some instances, laws may require Goodbody to hold certain information for specific periods other than those listed above.

5. WHERE IS MY DATA STORED?

The personal data that we collect from you may be transferred to, and stored outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA in which case the third country's data protection laws will have been approved as adequate by the European Commission or other applicable safeguards are in place. Further information may be obtained from our Privacy Team.

6. YOUR RIGHTS

Right of Access

Each person has the right to be advised, on request, whether we process their personal data and, where we do, to access that data. This includes the right to be advised of the purposes and period for which their data are processed and the names of any third parties with whom we share the personal data.

Right of Rectification

Each person has the right to have their data corrected, rectified or updated where they believe it may be inaccurate or incomplete.

Right of Erasure

Each person has the right to have their personal data erased, without undue delay, when the personal data are no longer necessary for the purpose for which it was collected and processed unless it is necessary for complying with a legal obligation.

Right of data portability

Individuals have the right to be provided with a copy of any personal data that we hold on them in a structured, commonly used and machine-readable format. They can request that information be transmitted directly to another party where it is technically feasible.

You may at any time request a copy of any of your personal data that we hold.

If at any time after giving us personal information you decide that you no longer wish us to hold or use this information, or in the case that the information becomes out of date, you should notify us, and we will remove or rectify the information within a reasonable time and in accordance with legislative requirements.

Privacy Notice - Job applicants

Introduction

Goodbody takes your privacy very seriously.

This Privacy Notice sets out how we collect and process your personal data, explains your rights and answers any queries you may have about your personal data.

This Privacy Notice only applies to the personal data of job applicants, potential candidates for employment, and our optional recruiting programs and events. It does not apply to our employees, contractors or clients, or other personal data that Goodbody collects for other purposes.

Unless we inform you otherwise during the recruitment process, Goodbody will be your data controller and will be the company to which you provide your consent for the processing of your personal data.

Our personal information handling policy and procedures have been developed in line with the requirements of the 1995 European Union Data Protection Directive (Directive 95/46/EC) and the General Data Protection Regulation (in force from 25 May 2018) and applicable national law.

1. WHAT INFORMATION DO WE COLLECT AND PROCESS?

We collect and process personal data about you when you apply for a job with us.

The personal data we process includes:

  • your name, home address, email address and/or phone numbers;
  • your date of birth, marital status, nationality and PPS number (where you provide this to us);
  • your educational and employment history;
  • other information contained within your CV or other documents or information you submit to us;
  • information from the selection process, if any;
  • references and assessments relating to your work for previous employers;
  • medical and financial information (where you provide this to us);
  • information to confirm your identity and right to work, such as a copy of your passport;
  • details of any unspent criminal convictions;
  • information relating to your feedback on our organisation; and
  • with your specific consent, information relating to your ethnicity, gender, nationality, disability, religion, sexual orientation and other diversity-related information.

By submitting your personal data to us, you acknowledge that:

  • you have read and understood this Privacy Notice and agree to the use of your personal data as set out herein;
  • you are not required to provide any requested information to us, but failing to do so may result in not being able to continue your candidacy for the job for which you have applied;
  • all your representations are true and correct to the best of your knowledge and belief, and you have not knowingly omitted any related information of an adverse nature. Providing any inaccurate information may make you ineligible for employment;
  • this Privacy Notice does not form part of any contract of employment offered to candidates hired by Goodbody.

2. WHAT IS THE SOURCE OF THIS INFORMATION?

We obtain this information directly from you, our personnel, through our systems and equipment, as well as from third parties such as recruitment agencies, universities, background checking companies, your referees, prior employers or Goodbody employees who have interviewed you. We may also obtain it from your public profiles available online.

We do not seek to obtain and will not collect sensitive personal data about a candidate unless we consider it necessary and its collection and processing is permitted under applicable laws.

3. HOW DO WE USE THIS INFORMATION AND WHAT IS THE LEGAL BASIS FOR THIS USE?

We process the personal data listed in paragraph 1 above for legitimate human resources and business management reasons including:

  • identifying and evaluating candidates for potential employment, as well as for future roles that may become available;
  • recordkeeping in relation to recruiting and hiring;
  • ensuring compliance with legal requirements, including diversity and inclusion requirements and practices;
  • conducting criminal history checks as permitted by applicable law;
  • protecting our legal rights to the extent authorized or permitted by law; or
  • emergency situations where the health or safety of one or more individuals may be endangered.

We may also analyse your personal data or aggregated/pseudonymised data to improve our recruitment and hiring processes and augment our ability to attract successful candidates.

We process your personal data for the purposes described above: when we have your consent to do so; when necessary to enter into an employment contract with you; when necessary for us to comply with a legal obligation; or when necessary for the purposes of our legitimate interests as an employer.

Where we wish to retain your personal data to consider you for future employment opportunities or to include you in one of our recruiting programs, we will seek your consent, either prior to or after you formally apply for a job opportunity.

4. WITH WHOM AND WHERE WILL WE SHARE YOUR PERSONAL DATA?

We may share your personal data for the purposes of intra-group administration. We may also share your personal data with our professional advisors such as our auditors and external legal and financial advisors.

Personal data may be shared with government authorities and/or law enforcement officials if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws. Personal data may also be shared with third party service providers who will process it on behalf of Goodbody for the purposes above. If any part of our business is sold or integrated with another business, your details may be disclosed to our advisors and those of any prospective purchaser and would be passed to the new owners of the business.

Individuals performing administrative functions and IT personnel within Goodbody may also have a limited access to your personal data to enable them to perform their jobs.

We may use third party service providers to support our recruitment process. We also share your personal data with other third-party service providers that may assist us in recruiting talent, administering and evaluating pre-employment screening and testing, and improving our recruiting practices.

We maintain processes designed to ensure that any processing of personal data by third party service providers is consistent with this Privacy Notice and protects the confidentiality, availability, and integrity of your personal data.

In addition, we may disclose or transfer your personal data in the event of a re-organisation, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.

5. HOW LONG WILL YOU KEEP MY PERSONAL DATA?

We will not keep your personal information for longer than is necessary and will only retain the personal information that is necessary to fulfil the purpose.

If you accept an offer of employment from us, any relevant personal data collected during your pre-employment period will become part of your personnel records and will be retained. If we do not employ you, we may, subject to your consent, retain and use your personal data for a period of time to consider you for potential future roles. Thereafter, we retain a minimum amount of your personal data to record your recruiting activity with us.

If you elect to join a recruiting program, we may retain your personal data to consider you for future employment opportunities and for a period of time specific to that program, unless you decide to opt-out prior to such time.

We will keep the personal data connected to your job application (including any interview records) for 12 months from the date of their creation by Goodbody or receipt from you. If your application is successful and you become a member of staff we will provide you with a copy of the Staff Privacy Notice. The retention periods referred to therein will apply to your personal data during your employment.

6. WHERE IS MY DATA STORED?

The personal data that we collect from you may be transferred to, and stored outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, in which case the other country's data protection laws will have been approved as adequate by the European Commission or other applicable safeguards are in place. Further information may be obtained from our Privacy Team.

7. WHAT ARE MY RIGHTS IN RELATION TO MY PERSONAL DATA?

Where you have consented to us using your personal data, you can withdraw that consent at any time.

If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it.

You also have the right, with some exceptions, to ask us to provide a copy of any personal data we hold about you.

Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format.

If you would like to request to access, review, or correct the personal data we have collected about you, or to discuss how we process your personal data, please contact careers@goodbody.ie

If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data (a) by withdrawing your consent for us to use it; (b) if it is no longer necessary for us to use your personal data; (c) you object to the use of your personal data and we don't have a good reason to continue to use it; or (d) we haven't handled your personal data in accordance with our obligations.

8. WHERE CAN I FIND MORE INFORMATION ABOUT GOODBODY’S HANDLING OF MY DATA?

Should you have any queries regarding this Privacy Notice, about Goodbody's processing of your personal data or wish to exercise your rights you can contact our Privacy Team using this email address: careers@goodbody.ie. If you are not happy with our response, you can contact the Data Protection Commissioner's Office: https://www.dataprotection.ie/


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Goodbody, its directors, employees, agents, affiliates or other representatives and their respective parent and associated companies, shall not be liable in respect of any claims, emergencies, demands, causes of action, damages, losses, expenses, including without limitation, reasonable legal fees and costs of proceedings arising out of or in connection with the use and/or dissemination of personal information relating to you in accordance with this privacy and cookies statement and your consents.

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