Privacy Policy



Gray Cunniffe Flaherty Ltd is committed to protecting and respecting 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 Gray Cunniffe Flaherty Ltd in relation to the information we collect about you.

For the purposes of the GDPR the Data Controller is:

  • NAME                 Gray Cunniffe Flaherty Ltd
  • ADDRESS            O’Connor Square, Tullamore, Co. Offaly
  • When we refer to ‘we’, ‘us’, ‘our’ and ‘ours’ it is Gray Cunniffe Flaherty Ltd.

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 We Are

Gray Cunniffe Flaherty Ltd are a General and Financial Services broker. Our principal business is to offer broad based advice based on a fair analysis basis and arrange transactions in relation to all classes of insurance policies.

Purpose for Processing Your Data

There are a variety of reasons why we need to gather information about you and they fall into the following categories:

  • Data to Identify you –

Name, date of birth, copies of ID, contact details, PPS number (or foreign equivalent), security details to protect identity, nationality, home status and address, email address, work and personal phone numbers, marital status, family details, tax residency and tax related information.

  • Your financial information –

Bank account details, credit/debit card details, application processing and administration records, your employment status and employment details of your partner, credit data from credit registers, credit agency performance data, life assurance, pension and investment details, transaction details, financial needs/attitudes, contact outcomes, authorised signatories details, information relating to power of attorney arrangements.

  • Your marital status.
  • Your financial associations.
  • Information about you provided by others or information provided by others about you, for example, joint policy applications –

If you give us information about someone else or someone gives us information about you, we may add it to any personal information we already hold and we will use it in the ways described in this Data Privacy Notice

  • Information that you have consented to us using-

Your consent to allow us to contact you in relation to relevant products and services *

  • Sensitive Data –

We may hold information about you which includes sensitive personal data, such as information relating to your health or a criminal conviction. We will only hold this data when we need to for the purposes of the product or services we provide to you or where we are legally obliged to do so.

  • Other Personal Information –

Telephone and image recordings, CCTV images at our office (for security reasons only) and information in relation to exercising your rights as a data subject.

Sometimes we might use your information even though you are not a client of ours. For example, you may be a beneficiary, guarantor, director, cardholder or a representative of a client of ours or a potential client applying for one of our products or services.

We will collect information:

  • You give us
  • Information from use of our products, services or website
  • Information provided to us by third parties

Why we are processing your data? Our legal basis.

In order for us to provide you with service or contract relating to the insurance products we provide, Gray Cunniffe Flaherty Ltd need to collect personal data in order to process or provide the relevant product. Our reason (lawful reason) for processing your data under the GDPR is:

  • Legal basis – Gray Cunniffe Flaherty Ltd needs to process your data as this is necessary in relation to a contract of insurance to which the individual as entered into or because the individual has asked for something to be done so that they can enter into a contract of insurance.

In any event, Gray Cunniffe Flaherty Ltd are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute and invasion of your privacy.

How will Gray Cunniffe Flaherty Ltd use the personal data it collects about me?

Gray Cunniffe Flaherty Ltd 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 any longer than is necessary.

Special Categories of Personal Data

If we collect any special categories for personal data (e.g. health, religious beliefs, racial, ethnic origin – financial information is not classifies as special categories of personal data) we will ensure the below:

  • We will obtain your specific consent

Who are we sharing your data with?

We may pass your personal data on to third-party services providers contracted to Gray Cunniffe Flaherty Ltd in the course of dealing with you. Any third parties that we may be sharing 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 date to fulfil the service, they will dispose of the details in line with Gray Cunniffe Flaherty Ltd’s procedures.

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

The third parties that we may pass your personal details to are:

  • Your authorised representatives
  • Third Parties with whom we need to share your information to facilitate transactions you have requested, and you ask us to share information
  • Service Providers who provide us with support services
  • Statutory and regulatory bodies (including central and local government) and law enforcement authorities
  • Third parties in connection with the sale or purchase of investment assets by us: persons making an enquiry or complaint, advice agencies and other regulated intermediaries, receivers, liquidators, examiners, official assignee for bankruptcy and equivalent in other jurisdictions including court orders
  • Trade associations and professional bodies, non-statutory bodies and members of trade associations
  • Pension fund administrators, trustees of collective investment undertakings and pension trustees, insurers and product producers
  • Healthcare professionals and medical consultants

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

Gray Cunniffe Flaherty Ltd 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 Gray Cunniffe Flaherty Ltd 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. Gray Cunniffe Flaherty Ltd will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body Central Bank of Ireland and our internal governance.

Implications of not providing your data

If we are collecting your data for a contract of insurance and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.

Profiling – Automatic Decision Making



The Main categories are:

· Risk Profiling -

To establish the customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the customer’s attitude to various levels of risk having answered a series of questions.

· Profiling for marketing purposes -

When we seek to contact you about other services, as outlined above * we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.

· Establishing affordability and providing quotations for financial services



We also use automated processing to assist in compliance with our legal obligations in connection with prevention of money laundering, fraud and terrorist financing for example to screen for suspicious transactions

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 comments or questions regarding this statement, please contact us on 057 9321515 or

Privacy policy statement changes

Gray Cunniffe Flaherty Ltd may change this privacy policy from time to time. When such a change is made, we will post a revised version on line. Changes will be effective from the point t which they are posted. It is your responsibility to review this privacy policy periodically so you are aware of any changes. By using our service you agree to this privacy policy.

This privacy was last reviewed in March 2020.