Personal Data….

This is information we may gather from you that will directly or indirectly identify you as individual. This type of data must be processed strictly in accordance with our Basis at Law stated in the table below. This data will include but may not be limited to:- 

Your title, name, postal address, risk address, gender, current and or previous occupation, date of birth, contact details,registration number, health conditions, bank details, credit / debit card details, credit searches, National Insurance Number, Next of Kin  information and children’s data where the child is under 16.

Special Categories of Data….

This is information we may gather from you that might reveal your health and insurance history. This data will be processed strictly in  accordance with the Basis at Law stated in the table below. This data will include but may not be limited to:- 

Your title, gender, physical or medical health conditions, driving licence origin, UK residency period, children’s data where the child is  under 16 and criminal history. Data for criminal convictions and offences will only be collected as permitted by UK Law.

Legal basis for processing

Why we collect 

your data

We obtain, collect and process your Personal Data and Special Categories of Data (which includes sharing your  data with others) to enable us to quote for your insurance needs, place you on cover, make any payment  arrangements requested, make any alterations to your policy that you may request during the policy term, and  in the unfortunate event that a claim occurs we will need to share your information to help you make your  claim. We may also have regulatory and / or legal obligations for sharing data with others, but we will only share it for the purposes stated, or in a way you would reasonably expect us to, unless we inform you otherwise. If  you do not provide the data requested it may not be possible to obtain a quote or provide you with a policy.

Our legal basis for  processing your  data

In order to arrange your insurance we will be using one or more of the following legal bases:- 

• In respect of children’s data, a child being a person under the age of 16, we will seek parental  consent to hold the data and record that consent. 

• Processing is necessary in order for us to take steps, at your request, to enter into a contract of  insurance when you ask us to place cover, and for the performance of that contract when you need  to make a claim. 

• Processing is necessary for us to comply with any legal or regulatory obligation 

• Where we believe a customer is vulnerable, processing might be necessary to protect the vital  interests of that person or other person covered by the policy 

• We may have a legitimate interest in processing the data for changes to any quotation or policy  which you may request, or for any other reason necessary to undertake any other requests related  to your insurance policy.

Who we share your data with and the  reason for  

processing

listed but not limited to the following:-

We are a Data Controller and in order to process your requests we may be sharing your data with one or more other Data Controllers. The Controllers we may share with and our reasons for sharing that information are 

Insurers 

Quotation, cover, to manage and progress claims

Insurance Providers, (Placing Brokers,  Delegated Authority Schemes,  

Wholesalers and the like)

Quotation, cover, to manage and progress claims

Loss Adjusters 

To manage and progress claims

Insurance Fraud Bureau 

Potential policy fraud

Loss Assessor 

To manage and progress claims

Financial Conduct Authority 

Regulatory obligations

Financial Services & Compensation  Scheme

Compensation in the event of insurer failure, if eligible

Financial Ombudsman Service 

Unresolved Complaints, if eligible

National Crime Agency 

Suspected criminal / fraudulent activity

HM Treasury Sanctions 

Checking clients are not on the banned list

Premium Finance Company 

Payment of premiums

Police 

Legal obligations

Possible Suppliers 

Insurers replacement facilities – ie, white goods,  

jewellers, cleaning companies, restoration companies,  approved repairers and garages, windscreen replacement company, plumbers, builders, electricians and the like. 

Staff 

Administering the quotation and policy, claims or payments.  Back Up Of Data

Claims Management Company 

To manage and progress claims

Surveyor 

Risk survey to analyse, report upon risk.  

Also in the event of a loss, the opportunity to survey  post-loss 

Debt Agency 

To collect unpaid premium due

It Providers – Software 

Holds all collective management information, system testing  when system not responding or errors occur

It Providers – Hardware, Cloud & Systems  Management

To detect issues, secure the system, and test the system.  Also backup of data

Interested Parties (Mortgage Lender) 

Proof of cover

Third Party Insurers 

To manage and progress claims

Third Party Assessor 

To manage and progress claims

Claims Management Company 

To manage and progress claims

Motor Insurers Database 

Registering vehicles to meet legislative requirements

Claims Exchange Underwriting 

Sharing of previous claims information between insurers

Employers Liability Tracing Office 

To provide confirmation of cover being in place

Our own Insurers 

Where we need to provide information about you

Solicitor 

Claims against clients or claims against us

Interpreter 

For management of the policy and claims where  

language is a barrier or they use sign language

Other Data Controllers not detailed  above

To be shared only for the purposes stated, or in a way  you would reasonably expect us to, unless we inform you  otherwise.

How long we  

retain your data

We will retain your Personal Data for as long as your insurance policy is valid with us and for 40 years thereafter.

IMPORTANT 

• For some of our products, we may carry out automated decision making (including profiling) to process your personal data  in order for insurers to underwrite and price your insurance online and/or process your claim. We take care to ensure our  profiling is fair, transparent and limited in purpose. 

• We have stated the reasons we are collecting your data above, but in the event that you do not wish to provide us with your  Personal Data for all or any ofthe above reasons, this may limit the insurers who will quote and agree to cover, and in some  cases insurers may not wish to offer cover at all.  

• If at any point in the future we need to amend this policy, every effort will be made to make you aware and our website  will always have the latest version.

Right to 

Be Informed

The General Data Protection Regulation sets out the information we must provide to you about your Data.  All of the information we are required to give you is contained within this Privacy Notice. If you do not  understand any part of this, you should contact us immediately and we will be happy to explain it to you.

Right of 

Access

You have the right to access and obtain a copy of the Personal Data, and any supplementary information that we  hold about you to enable you to verify the lawfulness of the processing carried out. This will be provided  free of charge, unless your request is unfounded, excessive or repetitive, and the information will be  sent to you within 30 days of your request being received. If we refuse your request, you have the right  to complain to the ICO.

Right to 

Rectification

You have the right to request that we correct any inaccuracies in the Personal Data we hold about you.  This will be corrected within one month. If we are unable to correct the inaccuracy you have the right to  complain to the ICO.

Right to 

Erasure

You have the right to request that we erase your Personal Data. For example, you may exercise this right  in the following circumstances: 

• your Personal Data are no longer necessary in relation to the purposes for which they were  collected or otherwise processed by us; 

• you withdraw consent and no other legal ground permits the processing; 

• you object to the processing and there are no overriding legitimate interests for the processing; • your Personal Data was unlawfully processed; or 

• your Personal Data must be erased for compliance with a legal obligation. 

We refuse the right to delete your information when it falls within our data retention period stated above,  as this data may be required to exercise or defend litigation in the event of a claim whether covered or not  by the insurance policy. If you do not agree with this you have the right to complain to the ICO.

Right to 

Restrict Processing

You have the righttorestrict our processing of your PersonalData where any of the following circumstances apply, although we will still be allowed to store it: 

• where you feel that the Personal Data which we hold about you are not accurate. Processing will  be restricted until you verify the accuracy of the information 

• where the processing is unlawful and you do not want your Personal Data be erased and request  the restriction of its use instead; 

• where we no longer need to process your Personal Data but the data may be required to  establish, exercise or defend a legal claim 

• where you have objected to our processing of your Personal Data pending the verification of whether or not our legitimate business interests override your interests, rights and freedoms. 

Where you exercise your right to restrict our processing of your Personal Data, we will only continue to  process it in accordance with the requirements of this policy or our legal obligations.

Right to  

Data Portability

You have a right to receive and transfer the Personal Data that we hold about you. This only applies to:- 

• personal data you have provided to us 

• where the data was processed by you giving us your individual consent or for the performance  of a contract 

• and where processing was carried out by automated means. 

Where you make such a request, this will be provided in a structured, commonly used, machine readable  format such as a CSV file or PDF. This will be completed within one month of us receiving your request. Repeat requests will incur a £10.00 administration fee. 

Right to 

Object to Processing

In certain circumstances, you have a right to object to our processing of your Personal Data  

• Where we have processed it as a legitimate interest (including profiling) 

• Direct Marketing (including profiling) 

We will still be able to process your Personal Data where  

• We can demonstrate compelling legitimate grounds for us to process your Personal Data which  override your interests, rights and freedoms 

• The processing is for establishment, exercise and defence of legal claims.

Right to 

Object to automated  decision making 

including profiling

You have a right not to be subjected to decisions being made solely by automated means without any  human involvement. This might be the case where quotations and cover are obtained online. We will still  be able to carry out this type of decision-making where:- 

• It is necessary to enter into or for the performance of a contract (such as a contract of insurance) which is the main reason we would use this type of decision-making; or 

• You have given your explicit consent for us to do so. 

We will only process data in the way you would expect it to be used, and you will be entitled to have a  person from our firm to review the decision so that you can query it and set out your point of view and  circumstances to us.

Right to 

Withdraw Consent

Where the legal basis of consent has been used (and in our business we only use this for parental consent  when collecting children’s data and marketing), you have the right to withdraw that consent at any time.  Where you exercise your right to withdraw parental consent of the processing of any children’s data, any  data processed prior to the withdrawal of consent will remain valid.