1. What is a Privacy Notice and why is it important?
We know your personal information is important to you and it is important to Ark Life too. This Privacy Notice tells you what we use your personal information for and explains your rights around how we use it. Please read this Privacy Notice to understand how and why we use your personal information.
If you give us personal information about someone else, please make sure you have their permission and make them aware of this Privacy Notice, as it also applies to them.
2. What personal information we collect and why
Needed for your contract:
We need to collect and use your personal information to provide your plan contract. This includes information such as your name, date of birth, contact and bank account details. We will ask for other information depending on the plan type and this can include health, employment, pension and salary information. We restrict access to, and use of, any sensitive personal information. We also create new personal information such as your plan value and benefits.
Personal information needed for plan contracts is held and used to:
- make and receive payments;
- provide you with information about your plan;
- administer your plan and pay benefits;
- provide customer care and service;
- contact you to inform you of any relevant actions you may need to take; and
- improve our services.
Required by law:
We may use your personal information to comply with law and regulations:
- reporting to regulators, law enforcement authorities or Revenue;
- keeping proper books and records; and
- actuarial analysis and risk management to ensure the company stays financially sound.
We carry out internal reporting, quality checking, compliance controls and audits to help meet these obligations.
We must collect certain personal information to comply with Anti-Money Laundering law.
- Up to date proof of identification and address
- Screening of all customers against Financial Sanctions, Politically Exposed Persons (PEP) and other official lists. To do this, we use your name, date of birth, address, nationality and occupation information.
Where needed we carry out searches of publicly available information. You must give us your tax residence information and tax identification number for tax reporting if required by legislation.
Under regulations we must give you information and updates on your plan. To do this, we use your plan and contact details.
When you give us your personal information we will check to see if we already have a record of you. This helps us to comply with your Data Protection rights. Please see section 8 of this Privacy Notice.
If you visit our offices we will record CCTV footage for safety and security reasons. We only hold these recordings temporarily and for longer if we need to for safety and security investigations.
Ark life legitimate interest:
We use your personal information for our legitimate interests as shown below. This doesn’t affect your privacy rights. We have taken account of any privacy risks and ensured that your data protection rights are not affected. We believe these uses benefit our customers. You can contact us if you have any questions using the details in section 9 of this Privacy Notice.
• Call Recording:
For customer service, we may record and monitor calls. We let you know if a call is being recorded at the start of the call so you can decide to continue or not.
• To Help Prevent and Detect Crime, Fraud and Money Laundering
We’ll need to evidence your identity
• Manage Legal Claims
Information may be used to bring about, defend and manage legal claims
• Product Enhancement and Governance
We may process your information to make sure our products continue to meet customer needs. This may lead to further product enhancement or development.
• Processing Information which is strictly necessary to ensure information, system, network and data security
This makes sure appropriate safeguards are in place to protect all information held on our systems
• Processing Information relating to your appointed beneficiaries / third parties
You may tell us who you’d like to benefit from your policy in the event of your death, or appoint representatives on your behalf such as trustees or power of attorney. We’ll process and store this on our systems.
• General Corporate Operations and Due Diligence including Mergers and Acquisitions
In the event of corporate operational requirements, or a merger or acquisition, we may need to share your information internally within the Group and with third parties as part of our due diligence and transaction.
• Protection detection and investigation of security incidents – processing of personal data to identify underlying compromised data
Whilst we have appropriate controls in place to protect your information, in the event of a cyber breach your data may be processed to identify whether it was compromised.
• Sharing with your Broker or Financial Adviser:
We recommend all our customers get financial advice to make sure their plan suits their needs. We share your personal information with AIB or financial adviser and keep them up to date on your plan. This allows them to give you better advice.
• Statistical and Research Analysis:
- We combine and group personal information for analysis to help us understand our customers.
- Personal information from other companies within the Phoenix Group may also be used for this
• Sharing with Other Insurers
If you told us you have similar cover in place with other insurers for certain plans we will validate that information with the other insurer(s). If you tell other insurers about similar cover you have in place with us for certain plans we will confirm this information to other insurers.
You have the right to object to your information being processed in these ways. However if you do object, Ark Life may be unable to administer your policy or make payments to you.
With your consent:
You are given the choice to provide consent, or not. In general we do not rely on consent to process your information. If we use consent, we will explain what we need it for and how you can change your mind in the future.
3. Consent and how to withdraw consent?
If we process your personal information based on consent, you have the right to withdraw that consent at any time. The opt-out methods will depend on how the consent was collected and will be explained when you give us your consent.
You will also be able to withdraw consent by contacting us directly using the details in section 9 of this Privacy Notice.
4. How and where do we get your personal information from?
You provide us with your personal information directly when you contact us, complete our forms or speak with us.
We also get personal information from agents, brokers, financial advisers, solicitors, private investigators, service companies who provide third party administration, law enforcement and fraud prevention agencies to prevent and detect crime, third parties acting on your behalf, any publicly available information as needed, employers or regulators (where relevant).
If you are the person insured under a protection plan, we will get relevant health information from health professionals. If we have accepted your cover based on a proposal and underwriting decision with another insurer we will get relevant personal information and personal health information from that insurer in order to process any claims.
We will check if you have similar cover or claims already in place with other insurers for certain plans in line with Revenue rules.
We also create new information about you based on information you have given us and through your interactions with us.
5. Who do we pass your personal information to?
We pass personal information to:
• Data processors:
Companies that act as service providers under contract with us and only process your personal information as instructed by us. Your personal information is transferred securely and is not used by other parties for any other reason. Our main Data Processor is Irish Life Financial Services Ltd. The categories of services that we use other Data Processors for include: IT, document management, administration, underwriting, customer services, actuarial services, Financial Sanctions and PEP screening.
• Brokers or Financial Advisers:
who you have chosen to act as your intermediary to give service and advice on your plan.
who you have chosen as your adviser to give service and advice on your plan.
appointed in connection with the plan contract.
• Health Professionals:
where needed for underwriting and paying benefits.
that we have a contract with to underwrite our plans and claims. To view the privacy notice of any our reinsurers please visit their website. You can see our current panel of reinsurers at https://www.arklife.ie/ark-lifes-reinsurers.
• Investment Service Providers:
We pass limited personal information to investment service providers where you want to access these services through your plan e.g. Stockbroker or Online Trading Platform.
• Private Investigators:
We engage private investigators to trace beneficiaries, identify and reduce fraud, and for good claims management. This is carried out in line with the Private Investigators Code of Practice.
Regulators and the Revenue Commissioners or as needed to comply with regulations and laws.
• Other Companies:
We pass your personal information to other companies within the Group for legitimate interest purposes. We also pass your personal information to companies engaged in customer research & experience measurement in order to improve customer service.
• Other Insurers
For assessing claims if we accepted your cover based on a proposal and underwriting with another insurer or for checking if you have similar cover of claims in place for certain plans in line with Revenue rules.
To receive premium payments and pay claims
• Fraud Prevention Agencies
To help us to prevent and detect financial crime and fraud
• Law Enforcement Agencies
To help them to comply with legal and regulatory requirements
To help us provide and receive information in connection with your pension scheme
6. Do we transfer your personal information outside of the EU?
The majority of your personal information is processed in Ireland.
However some of your information may be processed by us or the third parties we work with outside of the EU, including in the UK. Where we, or our data processors, transfer your personal information outside the EU, we will take steps to ensure that your personal information is protected to at least an equivalent level as it would be applied by Irish data privacy laws.
7. How long do we keep your personal information for?
We keep personal information for as long as you have a relationship with us. We also hold it after this where we need it for complaints handling, legal claims, for system back-ups and for as long as we have to under regulations.
8. What are your rights?
You have a number of rights over your personal information which you can exercise free of charge by contacting us using the details in section 9 of this
Privacy Notice. You will need to give us information to help us identify you and we will respond to you within one month in line with regulation. Any restrictions to your rights will be explained in our response.
• Right to Information
You have a right to the information set out in this Privacy Notice. The most recent version of our privacy notice will always be accessible on our website at www.arklife.ie. If we make any changes to the type of personal information we collect and / or how we use it we will inform you of the changes.
We have controls in place to protect your personal information and minimize the risk of security breaches. However should any breaches result in a high risk for you, we will inform you without undue delay.
• Right to Restrict or Object
You can restrict or object to any unfair and unlawful collection or use of your personal information.
You can object to any automated decision making that has a legal or similar significant impact for you and ask for the decision to be made by a person.
• Right to Correct and Update
You can ask us to correct and update personal information we hold about you.
Your Ark Life plans are long term contracts and to provide you with the best service it is important we have your up to date personal information, such as contact details.
• Right to Delete and Be Forgotten
You can request that we remove or delete your personal data if there isn’t a reason for us to continue to process it. Our regulator requires us to keep some information for a specific period.
We’ll consider each request to delete information on its own merits. If we can’t delete your information we’ll explain to you why we need to keep it.
If we agree to delete your information, we’ll also ask any third parties to remove any of your data that we shared with them.
• Right to Portability
You can ask for a copy of all personal information that you gave us (including through your interactions with us), and which we hold in an automated format. You can receive this in a machine readable format that allows you to keep it.
You may also request Ark Life to send this personal information in a machine readable format to another company. The format will depend on our ability to provide this in a secure way that protects your personal information.
It is unlikely we will be able to use a copy of your personal information sent to us in this way. This is because we can only collect personal information that we need. We also need your most up to date personal information to comply with regulations.
• Right to Access
You have the right to know what personal information we hold about you and to receive a copy of your personal information.
We must tell you:
- Why we hold it
- Who we pass it to, including whether we transfer it outside the EU
- How long we keep it for
- Where we got it from
- If we carried out any automated decisions, and if so, the logic behind it and what it means for you
This right does not allow you to access personal information about anyone else.
To access your personal information please contact us using the contact details in section 9 of this Privacy Notice. To help us respond as quickly as possible please let us know if you are only looking for copies of specific personal information.
9. How to contact us
You can contact with any questions about your personal information and this privacy notice:
Ark Life Assurance Company dac
PO Box 129
1890 252 364
10. Ark Life Data Protection Officer
Ark Life also has a Data Protection Officer that you can contact directly:
Ark Life Data Protection Officer
College Park House
If you do not think that we have processed your personal information in line with this Privacy Notice, please contact us.
If you are not happy with how we have processed your personal information or handled your privacy rights, you can complain to the Data Protection Commission by contacting them below:
Data Protection Commission,
Co. Laois, R32 AP23
Telephone: +353 761 104800
LoCall: 1890 252231