Privacy Statement

Wealth Management Ltd (WML) is committed to respecting and protecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.  

It is the intention of this privacy statement to explain to you the information practices of WML in relation to the information we collect about you.

For the purposes of the GDPR the data controller is:

  • WML
  • The contact details of WML is (01) 853 2243
  • When we refer to ‘we’ in this notice it is WML we are talking about

Please read this Statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.


Who are we?

WML are a financial services company dealing with High Net Worth Individuals and all their investment requirements, on a portfolio basis. Following an initial review of your existing assets and estate structuring, we agree a suitable strategy to match your requirements and risk profile.

WML is authorised by the Central Bank of Ireland as an:

  • Insurance Intermediary (European Communities (Insurance Mediation Regulations, 2005)
  • Investment Business Firm (Section 10 of Investment Intermediaries Act, 1995)
  • Investment Product Intermediary (Section 31 of the Investment Intermediaries Act, 1995)

The services provided include Portfolio Management, Retirement Planning and Personal Retirement Savings Accounts (PRSA’s), Succession Planning, Investment Funds, Structured Products, Insurance Broking including Income Protection, Savings Plans, Mortgage Protection, Life and Serious Illness Plans and Alternative Investments.

We provide a discrete and high level of service to a small number of individuals where the advantages of personal professional management of their personal financial affairs can be considerable.

Our nominated Data Protection Officer / GDPR Owner and data protection representative details are:

  • Fionnán O’Dwyer
  • (01) 853 2243


Purpose for processing your data

  • As part of any investment application made through WML, we are required to verify client identity details by way of photo identification (copy driver’s license or passport) and address details (copy of current utility bill) to provide Certified Anti Money Laundering documents. Application forms may also require Health Information in relation to Life or Serious Illness cover on behalf of Life companies.
  • This information will be maintained in a physical file for a period of 7 (seven) years with a copy of any application and any relevant correspondence for that investment/policy (or the lifetime of the investment/policy). It will also be shared with the relevant company in physical form or in digital form through scanning or email and on our computers with cloud based back up with encryption protection for the transfer of information.
  • The information collected will only be shared with the relevant life companies, stock brokers, Banks and/or your solicitor and accountant on your behalf (where applicable and as agreed with you).
  • We will shred non-essential documents after 7 (seven) years through an independent third party where it is delivered/collected securely and destruction is certified.


Why are we processing your data? Our legal basis

In order for us to provide you with a review of your Estate in the first instance, WML will need to collect personal data through a Client Contact Authorisation and Client Survey Document to assess what is required or feasible in the first instance.

Our reason (lawful reason) for processing you data under the GDPR is:

  • Consent to Contact In any event, WML are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.


How will WML use the personal data it collects about me?

WML will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.


Special categories of personal data

If we collect any special categories of personal data (e.g. health) – we will ensure the below:

  • we will obtain your explicit consent


Who are we sharing your data with?

We may pass your personal data on to third-party service providers contracted to WML in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide on your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with WML procedures.

If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your explicit consent, unless we are legally required to do otherwise.

The third parties that we pass your personal data to are:

  • Your Professional advisers
  • Solicitor/Accountant/Bank
  • Other specified persons

We have issued all our third party processors with a Data Processor checklist asking them GDPR specific questions

If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards and on condition that enforceable data subject rights and effective legal remedies for you the data subject are available.


Data subject rights:

WML facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request.

Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access: you have the right to request a copy of the information that we hold about you.
  • Right of rectification: you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten: in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing: where certain conditions apply to have a right to restrict the processing.
  • Right of portability: you have the right to have the data we hold about you transferred to another organisation.
  • Right to object: you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling: you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that WML refuses your request under rights of access, we will provide you with a reason as to why.

All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.


Additional information we are providing you with to ensure 

we are transparent and fair with our processing

Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. WML will process personal data in accordance with our retention schedule. This retention schedule has been governed by our internal governance.

In the event that you wish to make a complaint about how your personal data is being processed by WML or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and WML  data protection representatives Data Protection Officer / GDPR Owner

Failure to provide further information
If we are collecting your data for a contract (e.g. Life policy or Investment policy) and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.

Additional Processing
If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information prior to processing this data.


Contact Us

Your privacy is important to us. If you have any queries, questions or comments regarding this Statement, please do not hesitate to contact us.