State Savings is committed to complying with our obligations in respect of the processing of Personal Data under data protection laws. The purpose of this Data Protection Statement (“Statement”) is to ensure that we meet our transparency obligations pursuant to the General Data Protection Regulation (“GDPR”). The Statement sets out information about our duties and responsibilities regarding the protection of Personal Data.
State Savings (“we” or “us”) will collect and process your Personal Data, and other information in relation to your dealings with us, in connection with State Savings. This statement explains how we will manage your Personal Data connected with State Savings, why we use it, and how you may contact us.
Where we need to process your Personal Data or where we have a legal obligation to collect certain Personal Data relating to you (for example, in order to comply with our Anti-Money Laundering obligations), we will not be able to provide you with the product or service which you have requested if you do not provide this information to us.
2. Who we are
State Savings is the brand name used by the National Treasury Management Agency (“NTMA”) to describe the range of savings products offered by the NTMA.
When you put money into State Savings, you are placing your money directly with the Irish Government. All State Savings money is under the management of the NTMA. The repayment of all State Savings money is a direct, unconditional obligation of the Government of Ireland.
State Savings products are offered by the Minister for Finance acting through the NTMA pursuant to the powers conferred on the NTMA by the National Treasury Management Agency Act 1990 and the National Treasury Management Agency Act 1990 (Delegation of and Declaration as to Functions) Order 1990 (S.I. No. 277 of 1990).
State Savings is administered by An Post and Prize Bond Company as agents of the NTMA. The NTMA is the data controller for the Personal Data you provide, and An Post and the Prize Bond Company are the data processors acting on behalf of the NTMA.
For further information on how the NTMA may process your Personal Data, please see the NTMA Data Protection Statement at www.ntma.ie/information-pages/data-protection-statement/ or contact the NTMA Data Protection Officer at firstname.lastname@example.org.
3. Types of information we collect
Personal Data means any information which State Savings has or obtains or which you provide, such as your name, address, email address, telephone number(s) and date of birth, from which you can be directly or indirectly personally identified, and includes information such as identification documents, personal public service number (PPSN), account numbers, IP addresses and online identifiers.
State Savings may process Special Categories of Data (e.g. data relating to criminal offences or health) in limited circumstances, typically in relation to due diligence checks undertaken for anti-money laundering purposes, to investigate irregular account activity or where you have chosen to provide us with health information when making an enquiry about your account.
4. How we obtain your Information
We will obtain some of your Personal Data directly from you, such as when you complete an application form for State Savings and when you make a transaction on your State Savings account, including through our website and at a Post Office counter.
In addition, we obtain data about you when you make enquiries about State Savings products via a website form, an email enquiry (such as through Service@StateSavings.ie, PrizeBonds@StateSavings.ie) or at a Post Office counter.
We may also obtain some of your information indirectly, from a variety of sources, such as your joint account holder(s), and / or our service providers, such as vendors providing anti-money laundering and sanctions checking databases.
5. Why we hold and how we use your Information
We will use your Personal Data, but only to the extent necessary:
for the purposes of performing the contract you have entered into with us where you have purchased State Savings products , namely:
for the purposes of providing services to you, and setting up and administering your State Savings products;
to contact you if required in connection with, or to deal with queries, complaints or suggestions in relation to your State Savings products or transactions on or relating to your State Savings products.
for compliance with our legal obligations, including:
anti-money laundering and anti-terrorist financing (collectively “AML”) and fraud prevention purposes;
compliance with applicable tax and regulatory reporting obligations;
where we are ordered to disclose information by a court or other competent authority with appropriate jurisdiction.
for the performance of a task carried out in the public interest or in the exercise of official authority vested in the NTMA, including:
recording of telephone calls and electronic communications for fraud and crime prevention, to assist in improving customer services, to evidence instructions or to prevent or resolve disputes;
for day to day operational and business purposes, including board and group reporting and management purposes;
taking advice from our external legal and other advisors;
to help us improve our services and systems, and to improve your experience on our web and online services. Where possible An Post will use synthetic or anonymised data to carry out IT systems tests in order to improve services. In the event we use your personal data then we will restrict access to this data and will destroy this copy data after the testing is satisfactorily completed;
to undertake market research, statistical and product development analyses .
where necessary to establish, exercise or defend State Savings legal rights or for the purpose of legal proceedings.
6. When we disclose your Information
We will not disclose any of your Personal Data to any third party, except as outlined above and / or as follows:
where the disclosure is necessary to enable us to carry out our obligations under our agreement with you;
with another statutory body where there is a lawful basis to do so, for example, where it is necessary for fraud investigation or prevention;
to verify the authenticity of documentation provided to us (for example, we may use external databases and other address verification tools to verify a customer’s identity);
where we need to provide the Personal Data to counterparties to transactions entered into by you;
in the case of a joint account, to the other account holder(s);
to anyone providing a service to us or acting as our agents, which may include third party service providers(where we enter into agreements with third parties to process Personal Data on our behalf, we will ensure that the appropriate contractual protections are in place to safeguard such Personal Data);
where we need to share your Personal Data within State Savings, An Post Group as Agents of the NTMA, or with our auditors and our legal and other advisors;
to any (or any proposed) assignee, transferee, or successor in title to the whole or any relevant part of our business, and their respective officers, employees, agents and advisers; and
if we are under a legal obligation to disclose Personal Data or if State Savings believes in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other valid legal process, including protecting and defending State Savings’, or the An Post Group as Agents of State Savings’ rights and property.
We will not transfer your Personal Data outside of the European Economic Area without ensuring that appropriate measures such as EU-approved contract clauses are in place to protect it.
7. Retention of your Personal Data
Personal data will be retained for as long as required for the purpose for which the data was obtained and in accordance with our Retention Policy. Usually this means for the duration of your account and for a number of years afterwards sufficient to deal with any enquiries on the account, audits or claims.
8. Your rights in relation to your Personal Data
Updating and Correcting your Personal Data
If we hold incorrect Personal Data about you, you have the right to have the data amended. While we will use reasonable efforts to keep your Personal Data up to date, you will need to notify us without delay in the event of any change in your personal circumstances, so that we can keep the Personal Data up to date.
Customers can update their Personal Data by requesting the relevant forms either online by printing the relevant forms, signing these and submitting these to State Savings along with the relevant backup documentation to validate the change. These forms may also be requested through email at Service@StateSavings.ie, PrizeBonds@StateSavings.ie, or by calling the State Savings Call Centre on 1850 30 50 60 / 01 705 7200 between 08:00 and 20:00 Monday to Friday, and requesting the relevant form. You may also write to Customer Administration, State Savings, 3D, FREEPOST, GPO, Dublin 1, DO1 F5P2 setting out your request but also including:
Your name and address.
Your customer identification number and/or account number
A description of the specific Personal Data you wish rectified.
Right of erasure
You have the right in some circumstances to have your Personal Data, which we hold, erased. If you request an erasure of your Personal Data, all your data will be erased subject to the following important notice.
We will not be required to erase your data where to do so would prevent us from meeting our respective contractual obligations, or where we are required to process (including retaining) your Personal Data in order to comply with a legal obligation, or if the Personal Data is necessary to establish, exercise or defend State Savings legal rights or for the purpose of legal proceedings.
Right of Access
You have a right to be given a copy of your Personal Data on request, subject to certain exceptions. To request a copy of your Personal Data, please contact State Savings, 3D, FREEPOST, GPO, Dublin 1, D01 F5P2
Please note that we have the right to require that you identify yourself before we will respond to any access request.
You also have the right, in certain circumstances, to request a restriction on the use of your Personal Data and to object to certain uses of your Personal Data, in each case subject to the restrictions set out in applicable data protection laws. Further information on these rights, and the circumstances in which they may arise in connection with our processing of your Personal Data, can be obtained by writing to us at the address set out under “Contacting Us” below.
In any case where we rely on your consent to process your Personal Data, you have the right to change your mind and withdraw consent by writing to us at the address set out under “Contact Us” below.
You have the right to lodge a complaint about our processing of your Personal Data with the Data Protection Commission. See www.dataprotection.ie/. While you may make such a complaint, we request that you contact Sate Savings in the first instance to give us the opportunity to address any concerns that you may have.
9. Data Security and Data Breach
State Savings has a suite of Information Security Policies and Procedures which are designed to ensure that appropriate technical and organisational measures are in place to protect information. These measures protect Personal Data from unlawful or unauthorised destruction, use, loss, change, disclosure, acquisition or access. Personal Data are held securely using a range of security measures including, as appropriate, physical measures such as locked filing cabinets, IT measures such as ISO 27001, secure data centres and restricted access through approvals and passwords. We also take steps to ensure that only persons with appropriate authorisation can access your personal information.
In the event of a Personal Data breach, State Savings has implemented a Personal Data Breach Procedure and we will manage a Data Breach in accordance with this procedure.
10. Contacting Us
Any queries or complaints regarding our use of your Personal Data and / or the exercise of your individual rights should be addressed to the State Savings Data Protection Co-Ordinator, State Savings, Management Suite, GPO, O’Connell Street, Dublin 1, D01 F5P2.
Last updated May 2018