Privacy Notice

This Privacy Notice explains how Unio Financial Services Ltd collects, uses, and shares your personal data.

Unio Financial Services Ltd trading as Unio, Unio Wealth Management or Unio Employee Benefits is regulated by the Central Bank of Ireland as an Investment Intermediary under Section 10 of the Investment Intermediaries Act 1995 (as amended) and is registered as an Insurance Intermediary under the European Union (Insurance Distribution) Regulations, 2018.

Unio respects your right to privacy and committed to protecting your personal data.

The contents of this Privacy Notice are subject to change from time to time and any changes will be posted on our website and will be effective when posted. Each time you visit this website, the Privacy Notice in operation at that time will apply. Please review this Privacy Notice each time you use our website.

1.    Personal Data – what is it?

Personal data refers to information relating to a living person who may be identified directly or indirectly from that data. The processing of Personal data is governed by the General Data Protection Regulation 2016/679 (“GDPR”).

2.    What categories of Personal Data are processed?

The personal information we process may include the following:

  • Identification and demographic details, such as: Name, date of birth, gender, nationality, contact details (address, telephone number, email address), PPSN, passport number, driving licence,
  • Family and beneficiary details, such as: marital status, beneficiary details, power of attorney.
  • Employment details, such as: employer name, employee number, date of joining service, dates of absence, employment category, job title, employee benefit details, date of leaving service, salary and remuneration details.
  • Financial and pension information, such as: current and historic pension arrangements, pension contributions, insurance cover/underwriting details, bank details, utility bills.
  • Health information, such as: health status. From time to time sensitive or “special categories” of personal data may be processed, for example, data relating to your physical or mental health e.g. in circumstances where you retire early on grounds of ill health or for the purpose of obtaining insurance cover or processing a disability claim.

3.    How is Personal Data collected?

We collect the information about you in the following ways:

Information you provide us directly when you contact us, including when you visit and fill in forms on our website.

Information provided to us by Insurance Companies or your Employer or other relevant parties as part of the provision of certain services to you.

4.    Purposes for processing Personal Data:

We may process your personal data for the following purposes:

  • To provide Registered Administration services in relation to your membership of the pension scheme
  • To provide personal financial services to you including but not limited to assessing your financial needs and providing you with professional financial advice and recommendations
  • To provide administration services when joining a Group PRSA Scheme
  • To communicate with a product provider such as an Insurance Company or fund manager
  • To communicate with you by post, telephone, email or SMS, for the above purposes, (unless you instruct us not to do so in writing)
  • To initiate a product application if requested by you.

5.    Bases for Processing Personal Data

Contract & legal bases for processing Personal Data (acting as a data processor – Unio Employee Benefits)

The purposes stated in section 4 above are necessary for Unio Employee Benefits, acting as Data Processor, to carry out its activities on behalf of the trustees of a pension scheme to comply with their obligations as Trustee under the Pensions Act 1990 (as amended) which requires trustees to appoint a registered administrator and to maintain records and to comply with other legal obligations such as reporting to and liaising with the Revenue Commissioners for tax purposes or in response to a request or when dealing with the Pensions Authority or the Financial Services and Pensions Ombudsman in the event of an enquiry or complaint. The above purposes are also necessary and lawful for the performance of Employers’ contractual obligations (as Data Controllers) with regard to their employees.

Contract & legal bases for processing your Personal Data (acting as a data controller – Unio Wealth Management)

The purposes stated in section 4 above are necessary and lawful for Unio Wealth Management, acting as a Data Controller, to perform its contract with you for the provision of its services, including but not limited to, general consultancy services, investment consultancy services, insurance consultancy services and registered administration services where Irish Life Assurance PLC act as the Registered Administrator.

Also, Unio might process your data to comply with the requirements of the Central Bank of Ireland Code(s) of Conduct which include the Consumer Protection Regulations and to comply with legal obligations such as Anti Money Laundry, and reporting to and liaising with the Revenue Commissioners for tax purposes or when dealing with the Pensions Authority or the Financial Services and Pensions Ombudsman in the event of an enquiry or complaint.

Legitimate interest for processing your Personal Data

We may also process your personal data for the purpose of our legitimate interests such as:

  • Any analytics or data sharing with other service providers which are not for the purpose of managing the pension scheme of which you may be a member or performing the service, for example, EuroStat returns must be made to the Pensions Authority on an annual basis and member statistics are used for this purpose. The output of such analytics will not identify particular clients or individuals;

Processing your Personal Data with your consent

Subject to your consent, we may also process your Personal Data for the following purposes:

  • Sensitive or “special categories” of personal data: With your consent, we may process your personal information classed as sensitive. For example, if you retire early on grounds of ill health; or for the purpose of obtaining insurance cover or processing a disability claim.
  • Marketing: Where you have consented, we may use your personal information to contact you about our services.
  • Cookies: When you visit our website, we will ask for your consent to use cookies for purposes other than those strictly necessary for the operation of the site, such as enhancing your browsing experience and analysing site usage.

6.    Security of processing

Unio implements appropriate technical and organisational measures to protect the Data from unlawful or unauthorised processing and accidental loss, destruction or damage having due regard for the nature of the Personal Data concerned, the level of access to it, the nature, scope, context and purposes of the processing provided that such measures ensure a level of security appropriate to the risks to the rights and freedoms of Data Subjects that might result from unauthorised or unlawful processing or accidental loss, destruction or damage to the Data.

7.     Personal Data Retention

Unio retains your personal data for as long as you have a relationship with us, and where relevant, for an additional period as required by regulations.

If you avail of our services, the following retention periods apply:

  • Pension scheme members: Your personal data shall be processed and retained for the duration of your membership of the pension scheme for such time as the pension scheme is administered plus an additional 7 years; or for a date agreed with the trustees and/or the principal employer of the pension scheme.

 

  • Wealth Management personal client: Your data will be processed for seven years after the termination of our relationship.

If you provide us with personal information but do not proceed to avail of the requested service, we will seek your consent to retain that information for to 12 months.

The data is retained in accordance with the Unio destruction and data protection policy.

8.    Sharing of your Personal Data & transferring outside of the EU

Your personal data will be treated as strictly confidential but may be disclosed to the Pensions Authority, Revenue Commissioners, the Financial Services & Pensions Ombudsman, auditors, professional advisors, insurance companies and other service providers in connection with the services we provide you.

Your PPS number is your Personal Public Service Number. It is a unique identifier for use in transactions with public bodies such as the Revenue Commissioners and the Pensions Authority and is used by Unio for this purpose.

Your personal data is stored securely at all times. The vast majority of your personal data is stored securely and backed up within the EEA, however in some instances your data may be transferred to, processed and stored at, a destination outside the European Economic Area (“EEA”) subject to the provisions of GDPR being complied with by that processor. Details of the provisions applicable to such processors are available from the Head of Risk and Compliance.

Unio has appointed the following sub-processors:

Name of sub-processor Country location and full address of sub-processor Services/processing provided by the sub processor
Canada Life Group Services Irish Life Centre, Abbey Street Lower, Dublin 1 IT Services
Kefron Limited 53 Park West Road, Dublin 12 Document and information management and storage
Shred-it Ireland 6A, Westgate Business Park, Ballymount Road Upper, Ballymount, Dublin 24 Secure paper shredding and destruction services
Snap Sandyford Burtonhall Road Sandyford Dublin 18 Printing and graphic design services

9.    Your Rights

You have the right to raise objections in relation to the processing of your personal data, which may include a right to restrict such processing in certain instances. You also have a right to request a copy of your personal data and, in limited circumstances, to request its rectification or erasure. Where processing is based on your consent, you may withdraw that consent at any time. Any such queries, objections or requests should be directed to the Head of Risk and Compliance and will be processed in accordance with applicable data protection legislation, using the contact details below.

10.                       Contact Us

If you have any queries in relation to our Privacy Notice, please contact:

Head of Risk and Compliance

Email: Compliance@unio.ie

Address: Unio Financial Services Ltd, 2 Sandyford Business Centre

11.                       Complaints

If you wish to make a complaint about how your personal data is being processed by Unio or how your complaint has been handled, you have the right to lodge a complaint with our Head of Risk and Compliance, using the contact details above.

If you are not satisfied with how your query or complaint has been resolved, you have the right to raise the matter with the Office of the Data Protection Commissioner:

Data Protection Commission

21 Fitzwilliam Square South,

Dublin 2.

D02RD28

Web: www.dataprotection.ie

Email: info@dataprotection.ie

 

March 2026