Data Protection Policy

Data Protection Policy

Introduction
SmartChoice Financial Brokers Ltd. must gather and use certain information about individuals.
These can include customers, suppliers, business contacts, employees and other people the
organisation has a relationship with or may need to contact.
This policy describes how this personal data must be collected, handled and stored to meet the
company’s data protection standards thus complying with the legislation.
Purpose
This data protection policy ensures that SmartChoice Financial Brokers Ltd.:
• Comply with Data Protection Legislation and follow Good Practice;
• Protect the Rights of Employees, Customers and Partners;
• Is Transparent in terms of How It Stores and Processes Individuals’ Data;
• Protects itself from the Risks associated with a Data Breach.
Scope
Background to the General Data Protection Regulation (‘GDPR’)
The General Data Protection Regulation 2016 replaces the EU Data Protection Directive of 1995
and supersedes the laws of individual Member States that were developed in compliance with the
Data Protection Directive 95/46/EC. Its purpose is to protect the “rights and freedoms” of natural
persons (i.e. living individuals) and to ensure that personal data is not processed without their
knowledge, and, wherever possible, that it is processed with their consent.
Policy Statement
The General Data Protection Regulation (GDPR) describes how organisations — including
SmartChoice Financial Brokers Ltd., must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not
disclosed unlawfully.

The GDPR Is Underpinned by Six Important Principles Requiring That
Personal Data Be:
1. Processed lawfully, fairly and in a transparent manner;
2. Collected for specified, explicit and legitimate purpose;
3. Adequate, relevant and limited to what is necessary;
4. Accurate and where necessary, kept up to date;
5. Retained only for as long as necessary;
6. Processed in an appropriate manner to maintain security.
The Board of Directors of SmartChoice Financial Brokers Ltd. located at Unit 14A, Ashleigh Centre,
Main Street, Castleknock, Dublin 15 are committed to compliance with all relevant EU and Member
State laws in respect of personal data, and the protection of the “rights and freedoms” of individuals
whose information SmartChoice Financial Brokers Ltd. collects and processes in accordance with the
General Data Protection Regulation (GDPR).
The GDPR and this policy are applicable to all SmartChoice Financial Brokers Ltd. personal data
processing functions, including those performed on customers’, clients’, employees’, suppliers’ and
partners’ personal data, and any other personal data the organisation processes from any source.
The GDPR Owner is responsible for reviewing the register of data processing annually, in light of any
changes to SmartChoice Financial Brokers Ltd. activities (as determined by changes to the data
inventory register and the management review) and to any additional requirements identified by
means of data protection impact assessments (DPIA’s).
Partners and any third parties working with or for SmartChoice Financial Brokers Ltd. and who have
or may have access to personal data, will be expected to have read, understood and to comply with
this policy.
No third party may access personal data held by SmartChoice Financial Brokers Ltd. without having
first entered into a data confidentiality agreement, which imposes obligations on the third party no
less onerous than those to which SmartChoice Financial Brokers Ltd. is committed, and which gives
SmartChoice Financial Brokers Ltd. the right to audit compliance with the agreement.

Privacy Policy – Data Protection Principles
1. Be processed lawfully, fairly and in a transparent manner
The GDPR has increased requirements about what information should be available to data subjects,
which is covered in the ‘Transparency’ requirement.
Transparently – the GDPR includes rules on giving privacy information to data subjects in Articles
12, 13 and 14. These are detailed and specific, placing an emphasis on making privacy notices
understandable and accessible. Information must be communicated to the data subject in an
intelligible form using, clear and plain language.
The specific information that must be provided to the data subject must, as a minimum, include:
• the identity and the contact details of the controller and, if any, of the controller’s
representative;
• the contact details of the Data Protection Officer;

• the purposes of the processing for which the personal data are intended as well as the legal
basis for the processing;
• the period for which the personal data will be stored;
• the existence of the rights to request access, rectification, erasure or to object to the
processing, and the conditions (or lack of) relating to exercising these rights, such as whether
the lawfulness of previous processing will be affected;
• the categories of personal data concerned;
• the recipients or categories of recipients of the personal data, where applicable;
• where applicable, that the controller intends to transfer personal data to a recipient in a third
country and the level of protection afforded to the data;
• any further information necessary to guarantee fair processing.
2. Personal data can only be collected for specific, explicit and legitimate purposes
• Data obtained for specified purposes must not be used for a purpose that differs from those
formally notified to the supervisory authority as part of SmartChoice Financial Brokers
GDPR register of processing.
3. Personal Data must be adequate, relevant and limited to what is necessary
• The GDPR Owner is responsible for ensuring that SmartChoice Financial Brokers Ltd. do not
collect information that is not strictly necessary for the purpose for which it is obtained.
• All data collection forms (electronic or paper-based), including data collection requirements
in new information systems, must include a fair processing statement or link to a privacy
statement and be approved by the Data GDPR Owner.
• The Data GDPR Owner will ensure that, on an annual basis all data collection methods are
reviewed by internal audit to ensure that collected data continues to be adequate, relevant and
not excessive.
4. Personal data must be accurate and kept up to date with every effort to erase or rectify
without delay
• Data that is stored by the data controller must be reviewed and updated as necessary. No data
should be kept unless it is reasonable to assume that it is accurate.
• The GDPR Owner is responsible for ensuring that all staff are trained in the importance of
collecting accurate data and maintaining it.
• It is also the responsibility of the data subject to ensure that data held by SmartChoice
Financial Brokers Ltd. is accurate and up to date. Completion of a registration or application
form by a data subject will include a statement that the data contained therein is accurate at
the date of submission.
• The GDPR Owner is responsible for ensuring that appropriate procedures and policies are in
place to keep personal data accurate and up to date taking into account, the volume of data
collected, the speed with which it might change and any other relevant factors.
• On at least an annual basis, the GDPR Owner will review the retention dates of all the
personal data processed by SmartChoice Financial Brokers Ltd., by reference to the
• data inventory, and will identify any data that is no longer required in the context of the
registered purpose.

5. Personal data must be kept in a form such that the data subject can only be identified
for as long as is necessary for processing.
• Where personal data is retained beyond the processing date, it will be minimised,
encrypted/pseudonymised, in order, to protect the identity of the data subject, in the event of a
data breach.
• Personal data will be retained in line with the Retention of Records Procedure and, once its
retention date has passed, it must be securely destroyed, as set out in this procedure.
• The GDPR Owner must specifically approve any data retention that exceeds the retention
periods defined in the Retention of Records Procedure, and must ensure that the justification
is clearly identified, and in line with the requirements of the data protection legislation. This
approval must be in written format.
6. Processed in an appropriate manner to maintain security
• In determining appropriateness, the GDPR Owner, should also consider the extent of possible
damage or loss that might be caused to individuals (e.g. staff or customers) if a security
breach occurs, the effect of any security breach on SmartChoice Financial Brokers Ltd. itself,
and any likely reputational damage, including the possible loss of customer trust.
When assessing appropriate technical measures, the Data Protection Officer*/GDPR Owner will
consider the following:
• Password protection;
• Automatic locking of idle terminals;
• Removal of access rights for USB and other memory media;
• Virus checking software and firewalls;
• Role-based access rights including those assigned to temporary staff;
• Encryption of devices that leave the organisations premises such as laptops;
• Security of local and wide area networks;
• Privacy enhancing technologies such as pseudonymisation and anonymisation;
• Identifying appropriate international security standards relevant to SmartChoice Financial
Brokers Ltd..

When assessing appropriate organisational measures, the
GDPR Owner will consider the following:
• The appropriate training levels throughout SmartChoice Financial Brokers Ltd.;
• Measures that consider the reliability of employees (such as references etc.);
• The inclusion of data protection in employment contracts;
• Identification of disciplinary action measures for data breaches;
• Monitoring of staff for compliance with relevant security standards;
• Physical access controls to electronic and paper-based records;
• Adoption of a clear desk policy;
• Storing of paper-based data in lockable fire-proof cabinets;
• Restricting the use of portable electronic devices outside of the workplace;
• Restricting the use of employees own personal devices being used in the workplace;
• Adopting clear rules about passwords;
• Making regular backups of personal data and storing the media off-site;
• The imposition of contractual obligations on the importing organisations, to take appropriate
security measures when transferring data outside the EEA.

• These controls have been selected, based on identified risks to personal data, and the potential
for damage or distress to individuals whose data is being processed.
SmartChoice Financial Brokers Ltd. must demonstrate compliance with the
General Data Protection Regulation’s other Principles (Accountability)
The GDPR includes provisions that promote accountability and governance. These compliment the
GDPR’s transparency requirements. The accountability principle in Article 5(2). requires you to
demonstrate that you comply with the principles and states explicitly that this is your responsibility.
Data Subjects’ Rights
Data subjects have the following rights regarding data processing, and the data that is recorded about
them:
• To make subject access requests regarding the nature of information held and to whom it has
been disclosed;
• To prevent processing likely to cause damage or distress;
• To prevent processing for purposes of direct marketing;
• To be informed about the mechanics of automated decision-making process that will
significantly affect them;
• To not have significant decisions, that will affect them, taken solely by automated process;
• To sue for compensation if they suffer damage by any contravention of the GDPR;
• To act to rectify, block, erase, including the right to be forgotten, or destroy inaccurate data;
• To request the Supervisory Authority to assess whether any provision of the GDPR has been
contravened;

• To have personal data provided to them in a structured, commonly used and machine-
readable format, and the right to have that data transmitted to another controller;

• To object to any automated profiling that is occurring without consent.
Subject Access Requests
All individuals who are the subject of personal data held by SmartChoice Financial Brokers Ltd. are
entitled to:
• Ask what information the company holds about them and why;
• Ask how to gain access to it;
• Be informed about how to keep it up to date;
• Be informed about how the company is meeting its data protection obligations.
Should an Individual contact the company requesting this information, this is called a Subject Access
Request.
Subject Access Requests from individuals should be made by email, addressed to the data controller
at (email address). The data controller can supply a standard request form, although individuals do not
have to use this.
The data controller will aim to provide the relevant data within 30 days.
The data controller will always verify the identity of anyone making a subject access request before
handing over any information.

Consent
SmartChoice Financial Brokers Ltd. understands ‘consent’ to mean that it has been explicitly and
freely given, and a specific, informed and unambiguous indication of the data subject’s wishes that,
by statement or by a clear affirmative action, signifies agreement to the processing of personal data
relating to him or her. The data subject can withdraw their consent at any time.
SmartChoice Financial Brokers Ltd. understands ‘consent’ to mean that the data subject has been fully
informed of the intended processing and has signified their agreement, while in a fit state of mind to
do so and without pressure being exerted upon them. Consent obtained under duress or on the grounds
of misleading information will not be a valid basis for processing.
There must be some active communication between the parties to demonstrate “active consent”.
Consent cannot be inferred from non-responsive communications. The controller must be able to
demonstrate that consent was obtained for the processing operation.
For sensitive data, explicit consent from data subjects must be obtained unless an alternative
legitimate basis for processing exists.
Security of Data
All Employees/Staff are responsible for ensuring that any personal data that SmartChoice Financial
Brokers Ltd. holds and for which they are responsible, is kept securely and is not, under any
conditions, disclosed to any third party unless that third party has been specifically authorised by
SmartChoice Financial Brokers Ltd. to receive that information and has entered into a confidentiality
agreement.
All personal data should be accessible only to those who need to use it, and access may only be
granted in line with the Access Control Policy.
All personal data should be treated with the highest security and must be kept:
• in a lockable room with controlled access; and/or
• in a locked drawer or filing cabinet; and/or
• if computerised, password protected in line with corporate requirements in the Access Control
Policy; and/or
• stored on (removable) computer media which are encrypted in line with Secure Disposal of
Storage Media.
Care must be taken to ensure that PC screens and terminals are not visible except to authorised
Employees/Staff of SmartChoice Financial Brokers Ltd.. All Employees/Staff are required to enter
into an Acceptable Usage Agreement before they are given access to organisational information of
any sort, which details rules on screen time-outs etc.
Manual records may not be left where they can be accessed by unauthorised personnel and may not be
removed from business premises without explicit (written) authorisation. As soon as manual records
are no longer required for day-to-day client support, they must be removed from secure archiving in
line with your policies.
Personal data may only be deleted or disposed of in-line with the Retention of Records Procedure
Manual.

Records that have reached their retention date are to be shredded and disposed of as ‘confidential
waste’. Hard drives of redundant PCs are to be removed and immediately destroyed, as required
before disposal.
Processing of personal data ‘off-site’ presents a potentially greater risk of loss, theft or damage to
personal data. Staff must be specifically authorised to process data off-site.
Disclosure of Data
SmartChoice Financial Brokers Ltd. must ensure that personal data is not disclosed to unauthorised
third parties which includes family members, friends, government bodies, and in certain
circumstances, the Gardaí/Police. All Employees/Staff should exercise caution when asked to
disclose personal data held on another individual to a third party. It is important to consider whether
disclosure of the information is relevant to, and necessary for, the conduct of SmartChoice Financial
Brokers Ltd. business.
All requests to provide data for one of these reasons must be supported by appropriate paperwork and
all such disclosures, must be, specifically authorised by the GDPR owner.
Retention and Disposal of Data
SmartChoice Financial Brokers Ltd. shall not keep personal data in a form that permits identification
of data subjects for a longer period than is necessary, in relation to the purpose(s) for which the data
was originally collected.
SmartChoice Financial Brokers Ltd. may store data for longer periods if (1) there is a legitimate
reason for holding the data and (2) the personal data will be processed solely for archiving purposes in
the public interest, scientific or historical research purposes or statistical purposes, subject to the
implementation of appropriate technical and organisational measures to safeguard the rights and
freedoms of the data subject.
The retention period for each category of personal data will be set out in the Retention of Records
Procedure, along with the criteria used to determine this period, including any statutory obligations
SmartChoice Financial Brokers Ltd. has, to retain the data.
SmartChoice Financial Brokers Ltd. Data Retention, Data Disposal and Storage Removal Procedures
will apply in all cases.
Personal data must be disposed of securely, in accordance with the sixth principle of the GDPR.
Thus, processed in, an appropriate manner, to maintain security, thereby, protecting the “rights and
freedoms” of data subjects. Any disposal of data, will be done in accordance with the Secure
Disposal Procedure.
Data Transfers
All exports of data from within the Non-European Economic Area (EEA) countries (referred to in the
GDPR as ‘third countries’) are unlawful unless there is an appropriate “level of protection for the
fundamental rights of the data subjects”.
The transfer of personal data outside of the EEA is prohibited unless one or more of the following
specified safeguards, or exceptions, apply:

An Adequacy Decision
The European Commission can and does assess third countries, a territory and/or specific sectors
within third countries to assess whether there is an appropriate level of protection for the rights and
freedoms of natural persons. In these instances, no authorisation is required.
Countries that are members of the European Economic Area (EEA) but not of the EU are accepted as
having met the conditions for an adequacy decision.
A list of countries that currently satisfy the adequacy requirements of the Commission are published
in the Official Journal of the European Union. (Please see “Related Documentation” section below).
Assessment of Adequacy by the Data Controller
In Assessing adequacy, the UK based exporting controller, should consider the following factors:
• the nature of the information being transferred;
• the country or territory of origin, and final destination, of the information;
• how the information will be used and for how long;
• the laws and practices of the country of the transferee, including relevant codes of practice
and international obligations.
Privacy Shield
If SmartChoice Financial Brokers Ltd. wishes to transfer personal data from the EU to an organisation
in the United States it should check that the organisation is signed up with the Privacy Shield
framework at the U.S. Department of Commerce (DOC). The obligation applying to companies
under the Privacy Shield are contained in the “Privacy Principles”. The US DOC is responsible for
managing and administering the Privacy Shield and ensuring that companies live up to their
commitments. To certify, companies must have a privacy policy in line with the Privacy Principles
e.g. use, store and further transfer the personal data according to a strong set of data protection rules
and safeguards. The protection given to the personal data applies regardless of whether the personal
data is related to an EU resident or not. Organisations must renew their “membership” with the
Privacy Shield on an annual basis. If they do not, they can no longer receive and use personal data
from the EU under that framework.
Binding Corporate Rules(BCRs)
SmartChoice Financial Brokers Ltd. may adopt, approved binding corporate rules for the transfer of
data outside the EU. This requires submission to the relevant supervisory authority for approval of the
rules that SmartChoice Financial Brokers Ltd. is seeking to rely upon.
Model Contract Clauses
SmartChoice Financial Brokers Ltd. may adopt approved model contract clauses for the transfer of
data outside of the EEA. If SmartChoice Financial Brokers Ltd. adopts the (model contract clauses
approved by the relevant supervisory authority), there is an automatic recognition of adequacy.
Exceptions
In the absence of an Adequacy Decision, Privacy Shield membership, Binding Corporate Rules and/or
Model Contract Clauses, a transfer of personal data to a third country or international organisation
shall only take place on one of the following conditions:
• the data subject has explicitly consented to the proposed transfer, after being informed of the
possible risks of such transfers, for the data subject, due to the absence of an adequacy
decision and appropriate safeguards;
• the transfer is necessary for the performance of a contract between the data subject and the
controller, or the implementation of pre-contractual measures taken at the data subject’s
request;

• the transfer is necessary for the conclusion or performance of a contract concluded in the
interest of the data subject, between the controller and another natural or legal person;
• the transfer is necessary for important reasons of public interest;
• the transfer is necessary for the establishment, exercise or defence of legal claims; and/or
• the transfer is necessary to protect the vital interests of the data subject or of other persons,
where the data subject is physically or legally incapable of giving consent.
Data flow
SmartChoice Financial Brokers Ltd. has established a data inventory and data flow process as part of
its approach to address risks and opportunities throughout its GDPR compliance project namely;
• business processes that use personal data;
• source of personal data;
• volume of data subjects;
• description of each item of personal data;
• processing activity;
• maintains the inventory of data categories of personal data processed;
• documents the purpose(s) for which each category of personal data is used;
• recipients, and potential recipients, of the personal data;
• the role of SmartChoice Financial Brokers Ltd. throughout the data flow;
• key systems and repositories;
• any data transfers;
• all retention and disposal requirements.
SmartChoice Financial Brokers Ltd. is aware of all risks associated with the processing of, specific
types of personal data.
SmartChoice Financial Brokers Ltd. assesses the level of risk to individuals associated with the
processing of their personal data. Data Protection Impact Assessments (DPIAs) are carried out in
relation to the processing of personal data by SmartChoice Financial Brokers Ltd. and in relation to
processing undertaken by other organisations on behalf of SmartChoice Financial Brokers Ltd..
SmartChoice Financial Brokers Ltd. shall manage any risks identified by the risk assessment, to
reduce the likelihood of a non-conformance with this policy.
Where a type of processing, particularly using new technologies and considering the nature, scope,
context and purposes of the processing is likely to result in a high risk to the rights and freedoms of
natural persons, SmartChoice Financial Brokers Ltd. shall, prior to the processing, carry out a Data
Protection Impact Assessment (DPIA) of the impact of the envisaged processing operations on the
protection of personal data. A single Data Protection Impact Assessment (DPIA) may address a set of
similar processing operations that present similar high risks.
Following the result of a Data Protection Impact Assessment (DPIA), it is clear that SmartChoice
Financial Brokers Ltd. is about to commence processing of personal data that could cause damage
and/or distress to the data subjects, the decision as to whether SmartChoice Financial Brokers Ltd.
may proceed must be escalated for review to the GDPR Owner.
The GDPR Owner shall, if there are significant concerns, either as to the potential damage or distress,
or the quantity of data concerned, escalate the matter to the supervisory authority.

Data Protection Risks
This policy helps to protect SmartChoice Financial Brokers Ltd. from potentially, serious data
security risks, including:
• Breaches of confidentiality: for instance, information processed inappropriately;
• Reputational damage: for instance, the Company could suffer material or non-material
damage if hackers successfully gained access to sensitive data.
General Staff Guidelines
• The only people able to access data covered by this policy should be those who need it for
their work;
• Data should not be shared informally. When access to confidential information is required,
employees can request it from their line managers;
• SmartChoice Financial Brokers Ltd. will provide training to all employees to help them
understand their responsibilities when handling data;
• Employees should keep all data secure, by taking sensible precautions and following the
guidelines below;
• Strong passwords are mandatory, and they should never be shared;
• Personal data should not be disclosed to unauthorised people, either within the company or
externally.
• Data should be regularly reviewed and updated. If it is found to be out of date and/or no
longer required, it should be deleted and disposed of appropriately.
• Employees should request help from their line manager or the data protection officer if they
are unsure about any aspect of data protection.

Data Storage
These rules describe how and where data should be safely stored. Questions about storing data safely
can be directed to the IT manager or Data Controller.
When data is stored in paper format, it should be kept in a secure place where unauthorised people
cannot see it.
These guidelines also apply to data that is usually stored electronically but has been printed out for
some reason:
• When not required, the paper or files should be kept in a locked drawer or filing cabinet;
• Employees should make sure paper and printouts are not left where unauthorised people
could see them, like on a printer;
• Data printouts should be shredded and disposed of securely when no longer required;
• When data is stored electronically, it must be protected from unauthorised access, accidental
deletion and malicious hacking attempts;
• Data should be protected by strong passwords that are changed regularly and never shared
between employees;
• If data is stored on removable media (like a CD or DVD), these should be kept locked away
securely when not being used;
• Data should only be stored on designated drives and servers and should only be uploaded to
an approved cloud computing service.
• Servers containing personal data should be sited in a secure location, away from general
office space.

• Data should be backed-up frequently. Those back-ups should be tested regularly, in line
with the company’s standard backup procedures.
• Data should never be saved directly to laptops or other mobile devices like tablets or smart
phones.
• All servers and computers containing data should be protected by approved security
software and a firewall.

Data Usage
Personal data is of no value to SmartChoice Financial Brokers Ltd. unless the business can make use
of it. However, it is when personal data is accessed and used, that it can be at the greatest risk of loss,
corruption or theft. For example:
• When working with personal data, employees should ensure the screens of their computers
are always locked when left unattended.
• Personal data should not be shared informally. It should never be sent by email, as this
form of communication is not secure.
• Data must be encrypted before being transferred electronically. The IT manager can
explain how to send data to authorised external contacts.
• Personal data should never be transferred outside of the European Economic Area (EEA).
• Employees should not save copies of personal data to their own computers. Always
access and update the central copy of any data.
Data Accuracy
The law requires SmartChoice Financial Brokers Ltd. to take reasonable steps to ensure data is kept
accurately and up to date.
The higher the importance, that the personal data is accurate, the greater the effort SmartChoice
Financial Brokers Ltd. should put into ensuring its accuracy.
It is the responsibility of all employees who work with data to take reasonable steps, to ensure it is
kept as accurate and up to date as possible.
• Data will be held in as few places as necessary. Staff should not create any unnecessary
additional data sets;
• Staff should take every opportunity to ensure data is updated. For instance, by confirming
a customer’s details when they call;
• SmartChoice Financial Brokers Ltd. will make it easy for data subjects to update the
information SmartChoice Financial Brokers Ltd. holds about them. For instance, via the
company website;
• Data should be updated as inaccuracies are discovered. For instance, if a customer can no
longer be reached on their stored telephone number, it should be removed from the database.
• It is the marketing manager’s responsibility to ensure marketing databases are checked
against industry suppression files every six months.

Disclosing Data for Other Reasons
In certain circumstances, GDPR allows personal data to be disclosed to law enforcement agencies
without the consent of the data subject.
Under these circumstances, SmartChoice Financial Brokers Ltd. will disclose requested data.
However, the data controller will ensure the request is legitimate, seeking assistance from the board of
directors and from the company’s legal advisers, where necessary.

Providing Information
SmartChoice Financial Brokers Ltd. aims to ensure that individuals are aware that their data is being
processed, and that they understand:
• How their data is being used;
• How to exercise their rights.
To this end, the company has a Privacy Statement, setting out how data relating to individuals is used
by the company.
(This is available upon request. A version of this statement is also available on the Company’s
website).
Roles and Responsibilities
SmartChoice Financial Brokers Ltd. is a (Data Controller and Data Processor] under the GDPR.
Note: All Brokers are classified as Data Controllers
Top Management and all those in managerial or supervisory roles throughout SmartChoice Financial
Brokers Ltd. are responsible for developing and encouraging good information handling practices
within SmartChoice Financial Brokers Ltd.; responsibilities are set out in individual job descriptions.
Data Protection Officer/GDPR Owner
The Data Protection Officer/GDPR Owner have specific responsibilities in respect of procedures such
as the Subject Access Request Procedure and are the first point of call for Employees/Staff, seeking
clarification on any aspect of data protection compliance.
Compliance with data protection legislation is the responsibility of all Employees/Staff of
SmartChoice Financial Brokers Ltd. who process personal data.
SmartChoice Financial Brokers Ltd. Training Policy sets out specific training and awareness
requirements in relation to specific roles and Employees/Staff of SmartChoice Financial Brokers Ltd.
generally.
Employees/Staff of SmartChoice Financial Brokers Ltd. are responsible for ensuring that any personal

data about them and supplied by them to SmartChoice Financial Brokers Ltd. is accurate and up-to-
date.

Everyone who works for or with SmartChoice Financial Brokers Ltd. has some responsibility for
ensuring data is collected, stored and handled appropriately.
Each team that handles personal data must ensure that it is handled and processed in line with this
policy and data protection principles.
However, these people have key areas of responsibility:
• The board of directors is ultimately responsible for ensuring that SmartChoice Financial
Brokers Ltd. meets its legal obligations.
• The (data protection owner), (Aoife Foy), is responsible for:
o Keeping the board updated about data protection responsibilities, risks and issues;

o Reviewing all data protection procedures and related policies, in line with an agreed
schedule;
o Arranging data protection training and advice for the people covered by this policy;
o Handling data protection questions from staff and anyone else covered by this policy;
o Dealing with requests from individuals to see the data (Company Name), holds about
them (also called ‘Subject Access Requests’).
o Checking and approving any contracts or agreements with third parties that may
handle the company’s sensitive data.

Definitions
Definitions used by the company drawn from the General Data Protection Regulation (GDPR)
Material scope (Article 2.)
The GDPR applies to the processing of personal data wholly or partly by automated means (i.e. by
computer) and to the processing other than by automated means of personal data (i.e. paper records)
that form part of a filing system or are intended to form part of a filing system.
Territorial scope (Article 3.)
The GDPR will apply to all controllers that are established in the EU (European Union) who process
the personal data of data subjects, in the context of that establishment. It will also apply to controllers
outside of the EU that process personal data in order to offer goods and services, or monitor the
behaviour of data subjects who are resident in the EU.
GDPR Article 4. Definitions
Establishment
The main establishment of the controller in the EU will be the place in which the controller makes the
main decisions as to the purpose and means of its data processing activities. The main establishment
of a processor in the EU will be its administrative centre. If a controller is based outside the EU, it
will have to appoint a representative in the jurisdiction in which the controller operates to act on
behalf of the controller and deal with supervisory authorities.
Personal Data
Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable
natural person is one who can be identified, directly or indirectly, in particular by reference to an
identifier such as a name, an identification number, location data, an online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of
that natural person.
Special Categories of Personal Data
Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or
trade-union membership, and the processing of genetic data, biometric data, for the purpose of, uniquely
identifying a natural person, data concerning health or data concerning a natural person’s sex life or
sexual orientation.
Data Controller
The natural or legal person, public authority, agency or other body which, alone or jointly with others,
determines the purposes and means of the processing of personal data; where the purposes and means of
such processing are determined by European Union or Member State law, the controller or the specific
criteria for its nomination may be provided for by European Union or Member State law.

Data Subject
Any living individual who is the subject of personal data held by an organisation.
Processing
Any operation or set of operations which is performed on personal data or on sets of personal data,
whether by automated means or not, such as collection, recording, organisation, structuring, storage,
adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction, erasure or destruction.
Profiling
Is any form of automated processing of personal data intended to evaluate certain personal aspects
relating to a natural person, or to analyse or predict that person’s performance at work, economic
situation, location, health, personal preferences, reliability, or behaviour. This definition is linked to the
right of the data subject to object to profiling and a right to be informed about the existence of profiling,
of measures based on profiling and the envisaged effects of profiling on the individual.
Personal Data Breach
A breach of security leading to the accidental, or unlawful, destruction, loss, alteration, unauthorised
disclosure of, or access to, personal data transmitted, stored or otherwise processed. There is an
obligation on the controller to report personal data breaches to the supervisory authority and where the
breach is likely to adversely affect the personal data or privacy of the data subject.

Data Subject Consent
Any freely given, specific, informed and unambiguous indication of the data subject’s wishes by
which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing
of personal data.
The GDPR and Children
A child is defined currently, as being under the age of sixteen, but member states may consider
lowering the legal age of consent to thirteen. The processing of personal data of a child is only lawful if
parental or custodian consent has been obtained. The controller shall make reasonable efforts to verify
in such cases that consent is given or authorised by the holder of parental responsibility over the child.
Third-Party
A natural or legal person, public authority, agency or body other than the data subject, controller,
processor and persons who, under the direct authority of the controller or processor, are authorised to
process personal data.
Filing System
Any structured set of personal data which are accessible according to specific criteria, whether
centralised, decentralised or dispersed on a functional or geographical basis.