Privacy Policy and Fair Processing Notice

We are committed to protecting and respecting your privacy. This policy sets out how we may use any personal data we collect from you or that you provide to us. This policy is written in accordance with the European Union’s General Data Protection Regulation (GDPR).

  1. Who We Are

We are Independent Insurance Brokers, Mortgage Brokers and Financial Advisers, authorised and regulated by the Financial Conduct Authority. We act as intermediaries in advising on and helping you obtain suitable cover and/or protection with a wide range of insurers, investment companies and mortgage providers.

  1. Data We May Collect About You (Personal Data)

We may collect the following types of personal information from you, so we can undertake the activities listed in section 5 of this document.  These include:

Data Type Examples of data
Personal details Name, age, address, gender, date of birth, nationality
Family, lifestyle and social circumstances Marital status, dependents, employment history, hobbies and interests
Financial information Direct debit or payment card information, details of your income and debts, investments and pensions
Identification details Driving license, passport information, your National Insurance number
Claims Information about current or previous claims, (including other unrelated insurances) Data relating to your health, criminal convictions, or other special categories of personal data Risk details and other information about you which we need to collect to assess the risk to be insured and provide a quote Data relating to your health, criminal convictions, or other special categories of personal data. For certain types of policy, this may also include telematics data.
Non-alphanumeric data Photographs, video, voice recordings of telephone conversations and/or voicemail messages
  1. Data Collection

We might collect your personal data from various sources, including:

  • You
  • Your family members, employer or representative, business partners
  • Another unrelated person with whom you share the use of a car, or a home (such as a joint policyholder or additional driver)
  • Other insurance market participants such as insurers, underwriters, premium finance providers, risk surveyors
  • Credit reference agencies
  • Companies house
  • Anti-fraud databases, sanctions lists, court judgements and other databases
  • Government agencies such as the DVLA and HMRC
  • Open electoral register
  • In the event of a claim, third parties including the other party to the claim (claimant / defendant), witnesses, experts (including medical experts), loss adjustors, solicitors, and claims handlers

Which of the above sources apply will depend on individual circumstances. 

  1. The Purposes of Our Processing Your Personal Data

We use personal information in the following ways:

  • To provide quotes, process mortgage applications, effect and administer policies, administer investments and deal with claims
  • To administer third party claims, deal with complaints and prevent financial crime to meet our legal and regulatory obligations
  • To verify your identity
  • To manage our business and conduct market research to meet the legitimate needs of our business
  • To send marketing information if we have received your specific consent.
  1. Sharing Data

During our processing of your personal data as mentioned in section 5, we will share your data with other parties, which may include:

  • Insurers and their 3rd party software providers
  • Underwriting Agents
  • Mortgage Providers
  • Our Lloyd’s Broker/s
  • Loss Adjusters
  • Loss Assessors
  • Claims handling companies
  • Surveyors
  • Contractors appointed by you, your insurer, or their agents
  • Central Government
  • Regulatory Authorities and Ombudsmen that govern us
  • Credit Reference Agencies
  • Insurance Databases
  • Crime and fraud prevention agencies

The parties with which we share your personal data will depend on circumstances.

  1. Consent

To provide insurance cover and deal with insurance claims in certain circumstances, the parties mentioned in section 5 may need to process your special categories of personal data, such as medical and criminal convictions records, as set out against the relevant purpose.

Your consent to this processing may be necessary for the insurance market participant to achieve this.

You may withdraw your consent to such processing at any time. However, if you withdraw your consent this will affect our ability to administer your policy or to help you deal with a claim. 

  1. Profiling

As an intermediary we do not use any of your data for profiling.  All underwriting decisions that use profiling are made by the insurer or underwriter and sometimes this may be automated without any human intervention. Please refer to the insurer or underwriter’s Fair Processing Notice for details of how they use your personal data in these circumstances.  Please contact us if you need more information.

  1. Retention of Your Personal Data

We will only keep your personal data only for as long as we need it to:

  • Administer your insurance, investment and mortgage arrangements,
  • Deal with any claim or potential claim that may be made at a later date even after your policy has expired.

We are also bound by regulatory and legal requirements on data retention made by the Financial Conduct Authority (FCA) and HMRC which are currently seven years. 

  1. International Transfers

We use servers located in the United Kingdom and the European Union (EU) to store your personal information where it is protected by laws equivalent to those in the UK.

We may need to transfer your data to insurance market participants or their affiliates or sub-contractors located outside of the European Economic Area (EEA). These transfers will always be made in compliance with the GDPR. If you would like more details of how your personal data will be protected if transferred outside the EEA, please contact the data protection contact of the relevant party.

  1. Your Rights

If you have any questions in relation to our use of your personal data, please contact us first.

Under certain conditions, you may have the right to require us to:

  • Provide you with more details on the use we make of your personal data/special category of data;
  • Provide you with a copy of the personal data which you have provided to us (a data subject access request)
  • Update any inaccuracies in the personal data we hold (the right to rectification)
  • Delete any special category of data/personal data which we no longer have a lawful ground to use (the right to be forgotten)
  • Where processing is based on consent, to withdraw your consent so that we stop that particular processing (the right to withdraw consent)
  • Object to any processing based on the legitimate interests ground (the right to object) unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights
  • Ask us to restrict the use of your personal information in certain circumstances (the right of restriction)
  • Provide you with a copy of the personal data that you have provided to us (data portability)

In certain circumstances, we may need to restrict the above rights to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). 

  1. Complaints

You have the right to complain to the Information Commissioner’s Office (ICO) if:

  • You are not satisfied with our use of your personal data
  • You are not satisfied with our response to any request by you to exercise any of your rights in section 10
  • You think that we have breached the GDPR.

ICO contact details:

England Scotland Wales
Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Information Commissioner’s Office

45 Melville Street

Edinburgh

EH3 7HL

Information Commissioner’s Office

2nd floor

Churchill House

Churchill Way

Cardiff

CF10 2HH

Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate) Tel: 0131 244 9001 Tel: 029 2067 8400
Email: casework@ico.org.uk Email: scotland@ico.org.uk Email: wales@ico.org.uk
  1. Changes to Our Fair Processing Notice

Occasionally, we may need to make changes to this notice. When that happens, we will provide you with an updated version at the earliest opportunity. The most recent version will always be available on our website.

Moneynotion Limited 24/05/2018