HOW WE PROTECT YOUR PERSONAL INFORMATION
New European Union-wide data protection regulations are enforced from the 25th May 2018.
For the purposes set out in this notice, the Information Commissioner Office (ICO) requires us to advise you that, information including personal information detailed below relating to you or anyone else to be covered by an insurance policy will be collected and processed by Aquilla Insurance Brokers Ltd and or on its behalf by its third-party service providers.
What Information We Collect and Where This Comes From
We may collect personal data about you which may extend to include sensitive data from information provided by you when contacting us to request insurance quotations, claim notifications and the services provided by us in support of this. This data will be provided by you or any other person you may appoint to provide us with information. You may be completing application forms or answering questions we ask to provide us with the required information. We may also obtain information from other sources that is readily available in the public domain such as the Internet, Press etc.
The information we obtain from you may be passed onto your insurers, sub brokers (where applicable) claims adjusters, surveyors, government agencies and where required to do so we may be required to verity your identity and the accuracy of the information that has been provided.
This information will directly or indirectly identify you as an individual and may also provide information about your cultural or social identity. This type of data must be processed strictly in accordance with our Legal Basis of Processing Data stated below and may include but will not be limited to:
Your name, title, gender, race, civil status, contact details, postal or risk address, age, date of birth, medical & health information, employment & income information current or previous, criminal convictions or offences, bank details & credit searches, registration number, next of kin information.
This information might reveal personal information about you as an individual and may include but will not be limited to:
Your title, gender, race, ethnic origin, political opinions, religious beliefs, physical or medical health conditions, driving licence origin, UK residency period, children. Data for criminal convictions and offences will only be collected as permitted by UK law.
How and Why We Process Your Personal Data
We obtain, collect and process your Personal and Sensitive Data which will include us sharing this 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 this data to help you to make a 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 quotes or provide you with a policy.
Our Legal Basis of Processing Data
Processing is necessary in order for us to take steps, at your request to enter into a contract of insurance when placing cover on your behalf and to maintain the performance of the contract should you need to make any changes to the policy or if you need to make a claim. Where we believe a customer is vulnerable, processing might be necessary to protect the interests of that person or other persons covered by the policy.
It may also be necessary for us to process data to comply with any legal or regulatory obligations.
Who We Share Data With & The Reason For Processing
Where we are the Data Controller and in order for us to process your requests, we may be sharing your data with one or more other Data Controllers. The Controllers we may share Data with and our reasons for sharing that information are listed but not limited to the following:
|Insurers, Sub Brokers Underwriting Agencies, Debt Agency & Staff||Obtaining quotations, placing cover, policy maintenance, claims administration including recoveries, auditing & policy payment|
|Loss Adjusters, Loss Assessors, Claims
Management Companies, Third Party Insurers,
Third Party Assessors
|To manage the claims process|
|Surveyors||Risk surveyor to analyse and report to insurers or after a loss to undertake a post loss survey|
|Credit Reference Agency||To obtain quotations from some insurers and premium instalment plans|
|Interested Parties where noted on the policy
and Employers Liability Tracing Office
|Proof of cover|
|Claims Exchange Underwriting||Sharing of previous claims information between insurers|
|Solicitors||Handling claims against you or us or recovering third party claim recoveries. Contracts and Lenders agreements with your consent|
|Possible Suppliers||Involved in repairs or replacement following a claim|
|Financial Conduct Authority||Regulatory Obligations|
|Financial Ombudsman Services||Referral of unresolved complaint|
|Financial Services & Compensation Scheme||Compensation in the event of insurer failure (if eligible)|
|Insurance Fraud Bureau & National Crime Agency||Potential policy fraud or suspected criminal or fraudulent activity|
|HM Treasury Sanctions||Checking clients are not on the banned list|
|Police||Legal obligations and Fraud Protection Agencies|
|Mylicence (UK), DVLA, Motor Insurance
Bureau, Motor Insurance Database
|To meet legislative requirements|
|IT Providers – Software||Holds all collective management information, system testing when errors occur|
|IT Providers – Hardware, Cloud & Systems Management||To detect issues, secure the system and systems
|Aquilla’s Own Insurers||Where we are required to provide information about you|
We will retain your Personal Data for as long as your policy is valid with us and for up to 10 years thereafter.
We have stated the reasons we are collecting your data but, in the event that you do not wish to provide us with this for all or any of the above reasons this may limit the insurers who will quote and agree to provide cover.
Some products may carry out automated decision making including profiling to process your personal data in order for insurers to underwrite and price your quotation online and or process your claim. We will take care to ensure that this is fair, transparent and limited in purpose.
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.
Where we hold Your Data
At all times we will endeavour to hold your Data on servers within the UK, or within the European Economic Area (EEA). Where we share your information with other Data Controllers they must also agree to hold your Data within the EEA. However, in the unlikely event your data is to be held in any other geographical area we ensure that:
- Data Controllers do not do so without our prior consent
- An appropriate transfer agreement is put in place to protect your personal data
Your Acknowledgment of this Notice & Your Rights
Under the General Data Protection Regulation, you have rights, and these are listed below:
|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 one month 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:
We will 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 right to restrict our processing of your Personal Data where any of the following circumstances apply, although we will still be allowed to store it:
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 Portability||You have a right to receive and transfer the Personal Data that we hold about you. This only applies to:
Where you make such a request, this will be provided in a structured, commonly used, machine readable format. This will be completed within one month of us receiving your request.
|Right To Object To Processing||In certain circumstances, you have the right to object to our processing of your Personal Data:
We will still be able to process your Personal Data where
|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 are obtained online. We will still be able to carry out this type of decision-making where:
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 in connection with travel insurance), 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 the withdrawal of consent will remain valid.
If you would like to exercise any rights detailed above, please contact us.
You may raise any concerns about Aquilla Insurance Brokers Ltd processing of your Personal data with the ICO on https://ico.org.uk/
Changes To This Notice
We may amend this notice on occasion, in whole or part at our sole discretion. Any changes to this notice will be effective immediately upon sending the revised notice to you by email or post. If at any time we decide to use your Personal Data in a manner significantly different from that stated in this notice, or otherwise disclosed to you at the time it was collected we will notify you by email or post and you will have a choice as to whether or not we use your information in the new manner. If you have questions or concerns about this notice, please contact us.
Information About Or Provided By Another Person
Where your information for your policy has been provided to us by another person, we will send you a copy of this privacy notice directly to you, where we have your address, within one month of your policy being taken out. If we do not have your address, we will send a copy of this to the person arranging the insurance with instructions to pass this to you within one month.