Privacy Statement – McGee Auctioneers/HMG Entitlements
John McGee Entitlement Transfer Facilitator
This is your guide as to how your personal data is managed by
McGee Auctioneers/HMG Entitlements
We at McGee Auctioneers/ HMG Entitlements take your Data privacy very seriously. In this document it outlines our approach under the General Data Protection Regulation 2018 (GDPR).
1 Who we are
McGee Auctioneers/ HMG Entitlements has its registered office at Mountainpole Kells Co. Meath. PSRA licence number 003548.
2 Why do you need to collect information about me?
There are a number of reasons why McGee Auctioneers/ HMG Entitlements need to collect information. We need to be able to contact you, we need to be certain of your identity and we need to understand your circumstances so that we can offer you the most appropriate services and best possible customer experience.
3 What information will you collect?
The type of information that McGee Auctioneers/HMG Entitlements may collect or request from you includes:
- Your name, Address, contact phone numbers, email addresses, copies of ID (which may include your date of birth) and PPS number (or foreign equivalent).
- Bank account details
- Your herd number.
- Authorised signatory details, information relating to power of attorney arrangements.
- Your farm adviser details and who represents you with the Dept of Agriculture
- Information about you which may include sensitive personal data. We will only hold this data when and for as long as we need to for the purposes of the service we provide to you, or where we have a legal obligation to do so. We are required to treat and process the data as ‘sensitive personal data’ when we seek proof of address, your passport ID or driving licence ID in the context of compliance with our anti-money laundering obligations.
4 How do you collect information about me? And when do you do so?
We collect information about you in a number of different ways. For example:
- When you register with us to transfer Entitlements.
- When you or others give us information verbally or in writing.
- When your farm adviser contacts us on your behalf
- When you select us online on the Dept of Agriculture website
- How do you use my information?
5 We may use your data to contact you by phone, text message, email or other means but not in a way that is contrary to your instructions to us, your legitimate interest or contrary to law.
We may use your personal data for matters such as confirming your identity, to help us in the processing of an application for one of our services or to improve your customer experience with us.
Your data is used to manage and administer your file. Your data may also be used to process payments, e.g., if you have provided with your bank account details.
Personal data could be used to prevent and detect fraud, dishonesty and other crimes (such as preventing someone trying to steal your identity).
We need to use your information to manage and administer legal and compliance matters within McGee Auctioneers/ HMG Entitlements, including compliance with regulatory, legislative and voluntary codes of practice to which we have committed. We use your data to comply with your information rights, to establish your identity and to comply with laws and regulations concerning the prevention of money laundering, fraud and terrorist financing. As a result, we may need to disclose information to government and other statutory bodies. Your data may be used to comply with binding court orders, search warrants, requests to assist the Gardaí with the investigation or prevention of an offence and orders relating to requests for mutual legal assistance in criminal matters received from foreign law enforcement agencies.
6 Do you share my information with anyone else?
We only share your information with a certain number of other parties and we only do so as is necessary. Examples of information sharing here include:
- Agriculture Adviser who will have your permission to act on your behalf.
- Third parties we may need to share your information with in order to facilitate payments (e.g. banks credit and card issuers etc.) as well as those you ask us to share your information with.
- Authorised representatives – this would include your Attorney (under a Power of Attorney) or any other party authorised by you to receive your personal data
- Companies that provide support services for the purposes of protecting our legitimate interests. We only permit service providers to use your information in accordance with our instructions and they will have appropriate measures in place to protect your information. Our service providers include computer maintenance contractors, document storage and destruction companies, Farm advisers, auditors and other consultants, including legal advisers.
- Statutory and regulatory bodies (including central and local government) and law enforcement authorities. These bodies include bodies such as: the Data Protection Commissioner, the PSRA, An Garda Síochána/police authorities/enforcement agencies, the Revenue Commissioners, the Criminal Assets Bureau and US, EU and other designated authorities in connection with combating financial and other serious crime.
7 What about links on your website to other sites?
Our site may contain links to and from other websites. Third parties websites may also provide links to our site. If you follow a link to any of those websites please note that those websites and web platforms have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites. We do not accept, and we disclaim, any responsibility for the privacy statements and information protection practices of any third party website (whether or not such website is linked on or to the site). These links are provided to you for convenience purposes only, and you access them at your own risk. As such you are responsible to check the third party website’s privacy statements before you submit any personal data to their websites.
8 How long do McGee Auctioneers hold onto my information?
The length of time we hold your data is dependent on a number of factors, such as regulatory and statutory requirements. Other considerations are the type of data being held, whether the data is required for a legal dispute and whether you or a regulatory authority asks us to keep it for a valid reason.
As a general rule, your information is kept for a period of 7 years. However, if you request that McGee Auctioneers/ HMG Entitlements delete your data (prior to this 7 year period elapsing) we will process your request to the extent that we do not have a legal reason / obligation to retain the information.
9 What happens if I do not provide requested information to McGee Auctioneers/ HMG Entitlements?
We need your information in order to
- Provide our services to you
- Fulfil any contracts we have with you
- To manage our business for our legitimate interests
- To comply with our legal obligations.
10 What is the legal basis for McGee Auctioneers/ HMG Entitlements using my information?
We will use your data and may share that data where:
- Its use is necessary in relation to a service or a contract that you have entered into or because you have asked for something to be done so that you can enter into a contract with us or so that we can provide a service to you.
- Where the processing of special categories of data is necessary for the establishment, exercise or defence of legal claims.
- You have consented to the use of your data (including special categories of data) in a specific way.
- Its use is necessary because of a legal obligation that applies to us.
- Where you have made clearly sensitive categories of data about yourself public.
- Its use is in accordance with our legitimate interests. Where we process your information for our legitimate interests, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms. We may use your personal information to manage our everyday business needs including internal reporting, to progress and respond to legal claims and to prevent fraud. Our legitimate interest here is the effective management of our business.
11 What rights do I have under GDPR?
You have several rights in relation to how we use your information and we have significant obligations in this regard.
You have the right to:
- Find out if we use your information, to access your information and to receive copies of the information we have about you. When you contact us to ask about your information, we may ask you to identify yourself. This is to help protect your data. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you ask us otherwise.
- Obtain a transferable copy of certain data which can be transferred to another provider, known as “the right to data portability”. This right applies where personal information is being processed based on consent or for performance of a contract and the processing is carried out by automated means. The right also permits the transfer of data directly to another provider where technically feasible.
- Request that inaccurate information is corrected and incomplete information updated.
- Object to particular uses of your personal data where the legal basis for our use of your data is our legitimate business interests. However, doing so may have an impact on the services we can / are willing to provide.
- Object to use of your personal data for direct marketing purposes.
- Have your data deleted or its use restricted – you have a right to this under certain circumstances.
- We shall process your request without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar month period. Should this be necessary, we will explain the reasons why.
- Withdraw consent at any time, where any processing is based on consent. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.
- You have the right to complain to McGee Auctioneers/ HMG Entitlements or the Data Protection Commission or another supervisory authority. If you have a complaint about the use of your personal information, please let McGee Auctioneers/ HMG Entitlements know and we shall seek to resolve your issue as soon as possible. If you wish to make a complaint to McGee Auctioneers/ HMG Entitlements you may do so in person, by telephone, in writing or by email. Please be assured that all complaints received by us will be fully investigated. We ask that you supply as much information as possible to help us to resolve your complaint quickly.
Your Personal Data is held on secure servers hosted by our Internet Service Provider. We cannot guarantee or warrant the security of any information you transmit to us via the Internet, given that no data transmission over the Internet can be guaranteed to be 100% secure. However, we will take all reasonable steps to protect your Personal Data.
Privacy Statement – McGee Auctioneers
Last updated January 2020
This is your guide as to how your personal data is managed by McGee Auctioneers. We take Data privacy very seriously. This document outlines our approach under the General Data Protection Regulation 2018 (GDPR).